## TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

# AGENDA ITEM REQUEST

for Proposed Revision to the State Implementation Plan

AGENDA REQUESTED: June 22 , 2011

DATE OF REQUEST: June 3 , 2011

INDIVIDUAL TO CONTACT REGARDING CHANGES TO THIS
REQUEST, IF NEEDED: Joyce Spencer

, 239

- 5017

CAPTION: Docket No. 20 11

- 0 282

- SIP

. Consideration for publicat ion of, and hearing on, proposed Collin County Attainment Demonstration State Implementation Plan (SIP) Revision for the 2008 Lead National Ambient Air Quality Standard (NAAQS).

This proposed SIP revision would address Federal Clean Air Act (FCAA)

Section 191(a) requirements that states with lead nonattainment areas

submit to the EPA an implementation plan within 18 months of the designation effective date. Section 110(a)(1) of the Federal Clean Air Act (FCAA) requires states to submit a state implementation plan (SIP) revision for areas that have been designated nonattainment to provide for the implementation, maintenance, and enforcement of the NAAQS. State s are required to adopt and submit attainment demonstration SIP revisions within 18 months of designation. In accordance with FCAA, §172 and implementation guidance published with the November 12, 2008, final Lead NAAQS (73 FR 66964), the proposed SIP revi sion contains a reasonably available control measures analysis, a reasonably available control technology analysis, demonstration of attainment through air dispersion modeling, a control strategy demonstration, an emissions inventory, a demonstration of re asonable further progress, and contingency

measures. ( Holly Brightwell , Amy Browning) ( Non

- Rule Project No. 20 11

- 001

- SIP

- NR)

Susana M. Hildebrand Chief Engineer David Brymer

Division Director

Joyce Spencer Agenda Coordinator

Copy to CCC Secretary? NO X YES

# Texas Commission on Environmental Quality

Interoffice Memorandum

To:

Thru:

From:

Docket No.: Commissioners

LaDonna Castañuela, Chief Clerk Mark R. Vickery, P.G.

, Executive Director

Susana M. Hildebrand , P.E.

, Chief Engineer

20 11

- 0 2 82

- SIP Date: June 3 , 2011

Subject: Commission Approval for Proposed 2011 Collin County Attainment

Demonstration State Implementation Plan (SIP) Revision for the 2008 Lead National Ambient Air Quality Standard (NAAQS)

Short Title : 2008 Lead Attainment Demonstration SIP Revision

Non

- Rule Project No. 20 11

- 001

- SIP

- NR

Background and reasons for the SIP revision : On October 15, 2008, the United States Environmental Protection Agency (EPA) substantially strengthened the NAAQS for lead. The new standard, set at 0.15 microgra ms per cubic meter (μg/m 3 

### ) measured as a rolling three

- month average, is 10 times more stringent than the previous standard established in 1978 of 1.5 μg/m 3 

### measured as a quarterly average. Effective Decembe r 31, 2010, the EPA designated an area surroundin g Exide Technologies (Exide) located in Frisco, Collin County, as nona ttainment for the

2008 l ead NAAQS (75 FR 71033).

Section 110(a)(1) of the Federal Clean Air Act (FCAA) requires states to submit a SIP revision for areas that have been designated nonat tainment to provide for the implementation, maintenance, and enforcement of the NAAQS. States are required to adopt and submit attainment demonstration SIP revisions within 18 months of designation. In accordance with FCAA, §172 and implementation guidance published with the November 12, 2008, final Lead NAAQS (73 FR 66964), the proposed SIP revision contains a reasonably available control measures analysis, a reasonably available control technology analysis, demonstration of attainment through air dispersi on modeling, a control strategy demonstration, an emissions inventory, a demonstration of reasonable further progress, and contingency measures.

Scope of the proposed SIP revision : A.) Summary of what the SIP revision will do:

The 2008 Lead Attainment Demonstration SIP r evision would demonstrate attainment using an air dispersion modeling analysis that includes existing control strategies as well as the control strategies being implemented concurrently with this SIP revision. This S IP

revision also includes FCAA required elemen ts, including a reasonably available control

### Commissioners Page 2

June 3, 2011

Re: Docket No. 20 11

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- SIP

measures (RACM) analysis, a reasonably available control technology (RACT) analysis, demonstration of reasonable further progress (RFP), and a contingency plan.

The control measures and contingency measures th at have been identified for the 2008

Lead Attainment Demonstration SIP revision will be enforceable through an A greed O rder

between the Texas Commission on Environmental Quality ( TCEQ ) and Exide (Agreed

Order No . 2011

- 0521

- MIS ), the only lead source in the nonattainment area. To ensure compliance w ith the 2008 lead NAAQS, the Agreed Order is being proposed concurrently

with this SIP revision. The Agreed Order provide s enforceable measures to reduce emissions necessary for the Collin County lead nonattainment area to attain the 2008 lead NAAQS by November 1, 2012, and contain s contingency measures designed to ensure continued compliance with the standard.

B.) Scope re quired by federal regulations or state statutes:

In accordance with FCAA

, §172(c) and implementation gu idance published with the final

2008 l ead NAAQS (73 FR 66964), an attainment demonstration for lead must include the following elements:

• RACM and RACT analysis;

• dispersion modeling d emonstrating attainment by the required December 2015
deadline;

• c ontrol strategy demonstration;

• e missions inventory;

• c ontingency measures ; and

• d emonstration of RFP

.

Submission of RFP is typically separate from attainment dem onstration SIP submissions,

but in the case of lead nonattainment areas

, RFP is met by “adherence to an ambitious compliance schedule,” which is expected to periodically yield significant emission reductions. The EPA believes that the expeditious implement ation of RACM/RACT within the nonattainment area is an appropriate approach to RFP.

C.) Additional staff recommendations that are not required by federal rule or

state statute:

None

Statutory authority: The authority to propose and adopt th is SIP revision is derived from Texas Health and Safety Code, Texas Clean Air Act (TCAA), §382.002, which provides that the policy and purpose of the TCAA is to safeguard the state’s air resources from pollution; TCAA,
§382.011, which authorizes the c ommission t o control the quality of the state’s air; TCAA, §382.012, which authorizes the commission to prepare and develop a general, comprehensive plan for the control of the state’s air; and Texas Water Code, §5.02, General
Powers, and §5.013, General Jurisdiction of the Commission.

### Commissioners Page 3

June 3, 2011

Re: Docket No. 20 11

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FCAA, 42 United States Code §§7401, et seq

., requires states to submit SIP revisions that specify the manner in which the NAAQS will be achieved and maintained within each air quality control region of the state

. Additionally, the spe cific requirements for the 2008 l ead NAAQS were published in the No vember 12 , 2008

, issue of the Federal Register (73 FR

66964 ).

Effect on the: A.) Regulated community: The affected regulated community consists only of Exide , the sole significant contributing

source of lead in the nonattainment area. The affected source w ould be required to install

additional control technologies to meet the NAAQS

, implement new work practices, and comply with additional monitoring and recordkeeping requirements. For further

in formation, please refer to the e xecutive s u mmary in the narrative of the proposed 2008

Lead Attainment Demonstration SIP revision

, whi ch contains details of the contr ols set out in the Agreed Order

.

B.) Public: The general public in the Frisco area would benefit from improved air quality from reduced

lead emissions

.

C.) Agency programs: This SIP revision will have no new effect on agency programs

.

Stakeholder meetings: A stakeholder meeting for the proposed 2008 Lead Attainment Demonstr ation SIP

revision was held on January 19, 2011

, in Frisco. Stakeholders expressed numerous concerns about air quality, public health, industry

- related emissions, proposed control strategies, and property values.

Potential controversial concerns and legis lative interest : The City of Frisco, the citizens of Frisco, and the Honorable Florence Shapiro

, Texas

Senator District 8, have expressed considerable concern regarding Frisco’s air quality. Parties have also expressed great interest in expediting emission reductions at the Exide facility

.

Will this SIP revision affect any current policies or require development of new policies?

No

What are the consequences if this SIP revision does not go forward ? A re there

alternatives to this SIP rev ision ? The commission could choose to not comply with requirements to develop and submit this

lead attainment demonstration SIP revision to the EPA. If the 2008 Lead Attainment

### Commissioners Page 4

June 3, 2011

Re: Docket No. 20 11

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Demonstration SIP revision is not submitted by June 30, 2012, the EPA could issue a finding of failure to submit, requiring that the commission submit the required SIP revision within a specified time period, and imposing sanctions on the state. The EPA would be required to promulgate a Federal Implementation Plan (FIP) if the com mission failed to make the submission within two years. Sanctions could include tran sportation funding restrictions and grant withholdings. The EPA would be required to impose such sanctions and implement a FIP until it approved a replacement SIP for the a rea.

Alternatively, the commission could propose a SIP revision that relies on rule changes as the control strategy for the SIP. This would require the proposal, followed by a public notice and comment period for any rule changes and a different SIP revis ion.

Key points in the proposal SIP revision schedule: Anticipated proposal date: June 22 , 2011 Public hearing date: July 28, 2011 Public comment period : June 24 , 2011 through August 8 , 2011 Anticipated adoption date : December 7 , 2011

Agency contacts: Holly Brightwell , 239

- 4905

, Air Quality Division Amy Browning , 239

- 0891 , Environmental Law Division

cc: Chief Clerk, 2 copies

Executive Director ' s Office
Susana M. Hildebrand, P.E.

Anne Idsal

Curtis Seaton Ashley Morgan

O ffice of General Counsel Holly Brightwell Joyce SpencerREVISIONS TO THE STATE OF TEXAS AIR QUALITY

IMPLEMENTATION PLAN FOR THE CONTROL OF LEAD AIR

POLLUTION

COLLIN COUNTY LEAD NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

P.O. BOX 13087
AUSTIN, TEXAS 78711

- 3087

2011 COLLIN COUNTY ATTAINMENT DE MONSTRATION

STATE IMPLEMENTATION PLAN REVISION FOR THE

2008 LEAD NATIONA L AMBIENT AIR QUALIT Y

STANDARD

2011

- 001

- SIP

- NR

Proposal

June 22, 2011This page intentionally left blankES

- 1 On October 15, 2008, the United States Environmental Protection Agency (EPA) substantially strengthened the Nation al Ambient Air Quality Standard ( NAAQS ) for lead. The new standard 0.15 micrograms per cubic meter (μg/m EXECUTIVE SUMMARY

3 )

, measured as a rolling three

- month average, is 10 times more stringent than the previous standard of 1.5 μg/m 3 m easured as a quarterly average.

On O ctober 14 , 20 09, the governor of Texas submitted to the EPA a recom mendation that a portion of Collin County, surrounding the Exide Technologies’ (Exide) battery recycling plant
located in Frisco, Texas

, be designated as a lead nonattainment area. This recommendation was based on 2006 through 2008 monitoring data, air dis persion modeling, and analysis of

additional factors as prescribed by the EPA. On October 12, 2010

, the governor of Texas submitted an updated recommendation which reflected a permit amendment lowering Exide’s maximum permitted allowable emission rate and the resulting smaller nonattainment area. On November 22, 2010, the EPA designated the final recommended portion of Collin County as nonattainment for the 2008 l ead NAAQS, effective December 31, 2010 (75 Federal Register

Section 191(a) of the Federal Clean Air Act (FCAA) requires that states with lead nonattainment

areas submit to the EPA an attainment demonstration state implementation plan (SIP) revision

within 18 months of the effective designation date. The state is required to submit to t he EPA an

attainment demonstration SIP revision for lead by June 30, 2012, and to demonstrate that the

area wil l reach attainment of the 2008 lead NAAQS by the December 31, 2015

, attainment date. [ FR ] 71033).

This SIP revision demonstrates attainment using air dispersion modeling that includes control
strategies already in use at the Exide site as well as additional measures being proposed concurrently with this SIP revision

. This SIP revision a lso contains FCAA

- required elements, including a reasonably availabl e control measures analysis, a reasonably available control technology analysis, demonstration of reasonable further progress, and a contingency plan.

The control measures and contingency measures that have been identified for this proposed SIP

revision wi ll be enforceable through an agreed order between the Texas Commission on Environmental Quality ( TCEQ ) and Exide ( see Appendix A: Agreed Order 2011

- 0521

- MIS ), the only lead source in the nonattainment area. To ensure compliance with the 2008 lead NAAQS,

th e Agreed Order is being proposed concurrently with this SIP revision. T he Agreed Order provide s enforceable measures to reduce emissions necessary for the Collin County lead nonattainment area to attain the 2008 lead NAAQS by November 1, 2012, and contains contingency measures designed to ensure continued compliance with the standard.i SECTION V: LEGAL AUT HORITY



### A. The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the quality of the state’s air, including maintaining adequate visibility. General

The first air pollution control act, known as the Clean Air Act of Texas, was pass ed by the Texas Legislature in 1965

. In 1967, the Clean Air Act of Texas was superseded by a more comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477

- 5, Vernon’s Texas

Civil Statutes

. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989,
1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, and 2009

. In 1989, the TCAA was codified as Chapter 382 of the Texas Health and Safety Cod e.

Originally, the TCAA stated that the Texas Air Control Board (TACB) wa s the st ate air pollution control agency and the principal authority in the state on matters relating to the quality of air

resources

. In 1991, the legislature abolished the TACB effective September 1, 1993, and its powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource Conservation Commission (TNRCC )

. With the creation of the TNRCC, the authority over air quality is found in both the Texas Water Code and the TCAA

. Specifically, the authority of the TNRCC is found in Chapters 5 and 7

. Chapter 5, Subchapters A

- F, H

- J, and L, include the general provisions, organization, and general powers and duties of the TNRCC, and the responsibilities and authority of the executive director

. C hapter 5 also authorizes the TNRCC to impleme nt action when emergency conditions arise and to conduct hearings

. Chapter 7 gives the

TNRCC enforcement authority

. In 2001, the 77th Texas Legislature continued the existence of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the T exas Commission on Environmental Quality (TCEQ)

. In 2009, the 81st Texas Legislature, during a special session, amended section 5.014 of the Texas Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continued in existence by t he Texas Sunset A ct.

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in the state’s air and to control the quality of the state’s air by preparing and developing a general, comprehensive plan

. The TCAA, Subchapt ers A

- D, also authorize the TCEQ to collect information to enable the commission to develop an inventory of emissions; to conduct research and investigations; to enter property and examine records; to prescribe monitoring requirements; to institute enfor cement proceedings; to enter into contracts and execute instruments; to formulate rules; to issue orders taking into consideration factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; to conduct hearings ; to establish air quality control regions; to encourage cooperation with citizens’ groups and other agencies and political subdivisions of the state as well as with industries and the federal government; and to establish and operate a system of permits fo r construction or

modification of facilitie s.

Local government authority is found in Subchapter E of the TCAA

. Local governments have the same power as the TCEQ to enter property and make inspections

. They also may make

recommendations to the commission co ncerning any action of the TCEQ that affects their territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements with the TCEQ or other local governments

. In addition, a city or town may enact and enforce

ordinances for th e control and abatement of air pollution not inconsistent with the provisions of

the TCAA and the rules or orders of the commission.ii Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and
maintenance programs in certain area s of the state, consistent with the requirements of the Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies to develop and implement transportation programs and measures necessary to attain and

maintain the NAA QS; establish gasoline volatility and low emission diesel standards; and fund and authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated vehicle retirement programs.



### B. The following statutes and rule s provide necessary authority to adopt and implement the state implementation plan (SIP )

. The rules listed below have previously been submitted as part of the

SIP. Applicable Law

All sections of each subchapter are included, unless otherwise noted. Statutes

TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2009

TEXAS WATER CODE September 1, 2009

Chapter 5: T exas Natural Resource Conservation Commission Subchapter A: General Provisions Subchapter B: Organization of the Texas Natural Resource Conservation Comm ission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties of the Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§5.225, 5.22 6, 5.227, 5.2275, 5.231, 5.232, and 5.236) Subchapter H: Delegation of Hearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only) Subchapter M: Environmental Permitting Procedures (§5.558 only)

Chapter 7: Enforcement Subchapter A: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except §7.109) Subchapter E: Criminal Offenses and Penalties: §§7.177, 7.179

- 7.183

All of the following rules are found in 30 Texas Administrative Code, as of the following latest

effective dates: Rules

Chapter 7: Memoranda of Underst anding, §§7.110 and 7.119
December 13, 1996 and May 2, 2002

Chapter 19: Electronic Reporting March 1 5 , 2007

Chapter 35: Subchapters A

- C, K: Emergency and Temporary Orders and Permits; Temporary Suspension or Amendment of Permit Conditions July 20, 2006iii Chapter 39: Public Notice, §§39.201; 39.401; 39.403(a) and (b)(8)

- (10); 39.405(f)(1) and (g); 39.409; 39.411 (a), (b)(1)

- (6), and (8)

- (10) and (c)(1)

- (6) and (d); 39.413(9), (11), (12), and (14); 39.418(a) and (b)(3) and (4); 39.419(a), (b), (d), and (e); 39.420(a), (b) and (c)(3) and (4); 39.423 (a) and (b); 39.601

- 39.605 June 24, 2010

Chapter 55: Requests for Reconsideration and Contested Case Hearings; Public Comment, §§55.1; 55.21(a)

- (d), (e)(2), (3), and (12), (f) and (g); 55.101(a), (b), and (c)(6)

- (8); 55.103; 55.150; 55.152(a)(1), (2), and (6) and (b); 55.154; 55.156; 55.200; 55.201(a)

- (h); 55.203; 55.205; 55.209, and

55.211 June 24, 2010

Chapter 101: General Air Quality Rules May 12 , 2011

Chapter 106: Permits by Rule, Subchapter A May 12, 2011

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate

Matter July 19, 2006

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for Designat ed Facilities and Pollutants May 14, 2009

Chapter 114: Control of Air Pollution from Motor Vehicles December 13, 2010

Chapter 115: Control of Air Pollution from Volatile Organic Compounds February 17, 2011

Chapter 116: Permits for New Construction or Modif ication March 3 , 2011

Chapter 117: Control of Air Pollution from Nitrogen Compounds May 12, 2011

Chapter 118: Control of Air Pollution Episodes March 5, 2000

Chapter 122: §122.122: Potential to Emit December 11, 2002

Chapter 122: §122.215: Minor Permit Rev isions June 3, 2001

Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001

Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002

Chapter 122: §122 .218 : Minor Permit Revision Procedures for Permit Revisions Involving the Use of Economic Incentives, Marketable Permits, an d Emissions Trading June 3, 2001iv SECTION VI: CONTROL STRATEGY



### A. Introduction (No change)



### B. Ozone ( No Change )



### C. Particulate Matter (No change)



### D. Carbon Monoxide (No change)



### E. Lead ( Revised )



### 1. 1980 State Implementation Plan for the Control of Lead Air Pollution (No change)



### 2. 1993 Lead SIP Revisions for Collin County (No change)



### 3. 1999 Lead SIP Revisions for Collin County (No change)



### 4. 2009 Collin County Maintenance Plan for Lead (No change)



### 5. 2011 Collin County Attainment Demonstra tion SIP Revision for the 2008 L ead NAAQS (New)



### F. Oxides of Nitrogen (No change)



### G. Sulfur Dioxide (No change)



### H. Conformity with the National Ambient Air Quality Standards (No cha nge)



### I. Site Specific (No change)



### J. Mobile Sources Strategies (No change)



### K. Clean Air Interstate Rule (No change)



### L. Transport (No change)



### M. Regional Haze (No change)v TABLE OF CONTENTS

Executive Summary

Section V: Legal Authority

Section VI: Control Strategy

Table of Contents

List of Acronyms

List of Tables

List of Figures

List of Appendices

Chapter 1: General

1.1 Background

1.2 Introduction

1.3 Current SIP Revision

1.4 Summary of Measured Lead Concentrations in Frisco

1.5 Health Effects

1.6 Public Comment and Stakeholder Participation

1.6.1 Stakeholder Meetings

1.6.2 Public Hearings and Comment Information

1.7 Social and Economic Considerations

1.8 Fiscal and Manpower

Chapter 2: Emissions Inventory

2.1 Introduction

2.2 Point Sources

2.2.1 Emissions Inventory Development

2.2.2 Updated 2010 Emissions Inventory

2.3 Other Source Categories

Chapter 3: Air Dispersion Modeling

3.1 Introduction

3.2 Modeling Approach

3.2.1 Meteorology for Base Case and Future Case

3.2.2 Meteorology Sensitivity Analysisvi 3.3 Base Case Analysis

3.3.1 Base Case Emissions Inventory

3.3.1.1 Source Characterizations and Emission Rates

3.3.1.2 Other Sources

3.3.1.3 Background Sources

3.3.2 Source Input Parameters

3.3.3 Base Case Modeling Results

3.4 Future Case Analysis

3.4.1 Future Case Emissions Inventory

3.4.2 Background Sources

3.4.3 Source Input Parameters

3.4.4 Future Case Modeling Results

3.5 References

Chapter 4: Control Strategy And required Elements

4.1 Introduction

4.2 Existing Control Measures

4.3 RACT and RACM Analysis

4.3.1 Results of RACM (Including RACT) Analysis

4.3.1.1 RACM (I ncluding RACT) Determination

4.4 New Control Measures

4.5 Monitoring Network

4.5.1 Lead Monitoring Sites in Frisco

4.6 Contingency Plan

4.6.1 Contingency Measures

4.6.1.1 Contingency Measure Requirements

4.6.1.2 Contingency Trigger Levels

Chapter 5: Reasonable Further Progress

5.1 General

5.2 RFP Demonstration

5.3 RACM (Including RACT)vii LIST OF ACRONYMS

ADEC Alaska Department of Environmental Conservation

AERMOD American Meteorological Society/Environmental Protection Agency Regulatory

Model

ASOS Automated Surface Observing System

AQS Air Quality System

AQS ID Air Quality System Identification

BPIPPRM The Building Profile Input Program for Plume Rise Model Enhancements

CFR Code of Federal Regulations

DEMs digital elevation models

EAF electric arc furnaces

EPA United States Environmental Protection Agency

FCAA Feder al Clean Air Act

FR Federal Register

GEP good engineering practice

GPS Global Position System

HEPA high efficiency particulate air

ISHD Integrated Surface Hourly Data

IQ Intelligence Quotient

km kilometer

lb/hr pounds per hour

lb/hr•m 2

m/sec meters per second pounds per hour per square meter

mph miles per hour

NAAQS National Ambient Air Quality Standard s

NCDC National Climactic Data Center

NLCD National Land Cover Database

NWS National Weather Service

PTFE polytetrafluoroethylene

psia p ounds per s quare i nch a bsolute

R 2

SIP s tate i mplementation p lan correlation coefficient

SSE south

- southeast

TAC Texas Administrative Codeviii TACB Texas Air Control Board

TCAA Texas Clean Air Act

TCEQ Texas Commission on Environmental Quality (commission)

TNRCC Texas Natural Re source Conservation Commissio n

tons/hr tons per hour

tpd t ons p er d ay

USGS United States Geological Survey

μg/m 3

WESP Wet Electrostatic Prec ipitation m

icrograms per cubic meterix L I ST OF TABLES

Table 1

- 1: Monitoring Data from Collin County Lead Monitors

Table 1

- 2: Public Hearing Information

Table 3

- 1: Missing and Calm Hours in Meteorological Data

Table 3

- 2: Exide Source Description List

Table 3

- 3: Base Case Point Source Parameters

Table 3

- 4: Base Case Area Source Parameters

Table 3

- 5: Base Case Source Contribution at Location of Maximum Predicted Concentration

Table 3

- 6: Stack Test Details from Baghouses Covered Under Exide Permit 1147A

Table 3

- 7: Stack Test Details from Baghouses Covered Under Exide Permit 3048A

Table 3

- 8: Future Case Point Parameters

Table 3

- 9: Future Case Area Source Parameters

Table 3

- 10: Future Case AreaPoly Source Parameters

Table 3

- 11: Vertices of AreaPoly Source ROAD

Table 3

- 12: Future Case Source Contribution at Location of Maximum P redicted Concentrationx LIST OF FIGURES

Figure 1

- 1 Map of Collin County Lead Nonattainment Area

Figure 4

- 1 Collin County Lead (Pb) Nonattainment Areaxi LIST OF APPENDICES

Appendix

Appendix A Agreed Order Docket No. 2011

- 0521

- MIS Appendix Name

Appendix B Monitoring Data from Collin County Lead Monitors

Appendix C A nnual Emissions Inventory Update for Exide Technologies’ F risco Battery Recycling Plant

Appendix D Reasonably Available Control Measures (RACM) and Reasonably

Availa ble Control Technology (RACT) Analyses

Appendix E RACM RFP Implementation Schedule1

- 1 CHAPTER 1: GENERAL

1.1 BACKGROUND

The History of the Texas State Implementation Plan (SIP) , a comprehensive overview of the SIP revisions submitted to the United States Environmental Protection Agency (EPA) by the State of
Texas, is available on the Texas Commission on Environmental Quality’s (TCEQ) SIP

Introduction Web page ( http://www.tceq.texas.gov/airquality/sip/sipintro.html )

.

1.2 INTRODUCTION

The EPA designated a portion of Collin County as a lead n onattainment area for the 1978 L ea d National Ambient Air Quality Standard (NAAQS) on November 6, 1991 (56 Federal Register

**•** automate the scale and feed for the reverberatory furnace; [ FR ] 56694) . The EPA approved the Collin County lead attainment demonstration SIP revision for the 1978 NAAQS on November 29, 1994 (59 FR 60930) . The EPA redesignated the area to

attai nment and approved the first 10

- year maintenance plan in October 15, 1999 (64 FR 55421)

. In 2009, the TCEQ submitted to the EPA the second and final 10

- year maintenance plan for the

1978 l ead NAAQS. The maintenance plan included contingenc y measures to promptly correct any violat ion of the 1978 l ead NAAQS. Because there is only one significant lead source in the

nonattainment area

, all measures are directed at this source. The contingency measures included in the 2009 maintenance plan would require Exide Technologies’ battery recycling plant (Exide) to do one of the following if the area monitored lead concentrations above the 1978 lead NAAQS:

**•** expand the existing water misti ng dust suppression system; or

**•** implement an alternative measure that will provide, at a minimum, emissions reductions equivalent to those listed previously.

On November 12 , 2008 , the EPA substantially strengthened the NAAQS for lead. The new
standard, set at 0.15 micrograms per cubic meter (μg/m 3 ) measured as a rolling three

- month
average, is 10 times more stringent than the previous standard of 1.5 μg/m 3 measured as a quarterly average (73 FR 66964)

. On November 22

, 2010, the EPA designated a portion of C ollin County surrounding Exide as nonattainment for the 2008 l ead NAAQS, effective December 31, 2010 (75 FR 71033). The 2008 lead NAAQS final rule contained a revised method for calculating averaging time for the purposes of comparing monitored data to the NAAQS. Compliance with

the 2008 lead NAAQS is based on 36 three

- month rolling averages. For an ambient air monitoring site to meet this standard, no three

- month rolling average for the previous 36

months prior to the attainment date may exceed 0.15 μg/m 3

. Therefore, Collin County must monitor attainment of the NAAQS beginning November 1, 2012, to meet the December 31, 2015

, attainment deadline . Appendix B : Monitoring Data from Collin County Lead Monitors

1.3 CURRENT SIP REVISION describes available monitoring data in Collin County from the past 36 months.

Effective December 15, 2010, t he EPA designated a 1.28 square mile area surrounding Exide in

Frisco, Texas

, as nonat tainment for the 2008 lead NAAQS (75 FR 71033)

. T he nonattainment

area is a portion of Collin County located in the City of Frisco that is bounded to the north by

latitude 33. 153, to the east by longitude

- 96.822, to the south by latitude 33.131, and to th e west by longitude

- 96.837. Figure 1

- 1 : Map of C ollin County Lead Nonattainment Area provides a visual representation of the nonattainment area

. Lead nonattainment areas designated in 2010, are required to attain the 2008 l e ad NAAQS as expeditiously as practicable but no later than
December 31, 2015. Th e state must submit a SIP revision addressing the lead nonattainment1

- 2 area requirements of the Federal Clean Air Act (FCAA) by June 30 , 2012

. To ensure that the Collin County nonattainment area attains the 2008 lead NAAQS as expeditiously as practicable, this SIP revision includes control measures implemented during SIP development but prior to proposal as agreed upon by Exide

.

Figure 1

- 1 : Map of Collin County Lead Nonattainment Area

This proposed SIP revi sion demon strates attainment of the 2008 l ead NAAQS using an air dispersion modeling analysis and contains control measures necessary to bring Collin County into attainment by November 1, 2012. In addition to control measures included to demonstrate

attain ment by November 1, 2012 , this proposed SIP revision contains contingency measures to be implemented if the area fails to meet that deadline or fails to meet reasonable further

progress (RFP) requirements

. As required by the FCAA and the EPA’s implementation guidance for the 2008 lead NAAQS, this proposed SIP revision also contains a reasonably available control technology analysis, a reasonably available control measures analysis, and a n RFP

demonstration.

The control measures and contingency measures that have been identified for this proposed SIP

revision would be enforceable through Agreed Order 2011

- 0521

- MIS between the TCEQ and Exide, the only lead source in the nonattainment area

. To ensure compliance with the 2008 lead
NAAQS

, the Agreed Order is being proposed concurrently with this SIP revision

. The Agreed Order provide s enforceable measures to reduce emission s necessary for the Collin County lead

nonattainment area t o attain the 2008 lead NAAQS by No vember 1, 2012 , and contain s contingency measures designed to ensure continued compliance with the standard

.1

- 3 1.4 SUMMARY OF M EASURED LEAD C ONCENTRATIONS IN FRI SCO

The 2008 lead NAAQS final rule contained a revised method for calculating averaging time for the purposes of comparing monitored data to the NAAQS. Compliance with the 2008 lead
NAAQS is based on 36 three

- month rolling averages

. For an ambient air monitoring site to meet

thi s standard, no three

- month rolling average for the previous 36 months may exceed 0.15 μg/m 3

As of May 20

, 2011, the lead design value for Collin County is 0.71 μg/m . Collin County must monitor attainment of the NAAQS beginning with the November 1,

2012

, through January 31, 2013, three

- month rolling average to meet the December 31, 2015

, attainment date.

3

. Table 1

- 2: Monitoring Data from Collin County Lead Monitors describes the most recent 36

- month period of lead monitoring data in Collin County.

Table 1

- 1 : Monitoring Data from Collin County Lead Monitors

Monitor /A ir Q uality S ystem

Identification Number Highest 3

- month ambient air

concentration average in the

most recent 36

- month period
(μg/m 3 Most recent three

- month rolling

average

) ( μg/m 3

Eubanks 480850009 )

0.71 0. 49

Ash Street 480850007 0.15 0. 11

Parkwood 480850003 0.37 0. 11

Stonebrook 4808500 29 0.15 0.15

1.5 HEALTH E FFECTS

On October 15, 2008, the EPA substantially strengthened the NAAQS for lead. According to the

EPA ’s final rule for the 2008 l ead NAAQS (73 FR 66964) , scientific evidence about lead and health has expanded dramatically since the EPA issued the initial standard of 1.5 μg/m 3

Lead that is emitted into the air can be inhaled direct ly or ingested after it settles onto surfaces

or soils. H owever, for the general population, exposure to lead occurs primarily via ingestion through contact with contami nated soils or other surfaces. Once taken into the body, lead distributes throughout th e body in the blood and accumulates in the bones. Depending on the level of exposure, lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems, and the cardiovascular system. Lead exposure

also af fects the oxygen

- carrying capacity of the blood. in 1978.

M ore than 6,000 new studies on lead health effects, environmental effects, and lead in the air have been published since 1990. Evidence from health studies shows that adverse effects occur at much lower levels of lead in blood than previously thought.

Lead effects most commonly encountered in current populations are neurological effects in children and cardiovascular effects (e.g., high blood pressure and heart disease) in adults. Children are at a higher risk of exposure to lead when compared to adults. The risk of exposure is higher because children tend to put their hands and other objects

, which may contain lead

, into their mouths (e.g., lead

- based paint chips from older homes) . Children also have a hi gher risk of adverse effects because their brains are still developing. Infants and young children are especially sensitive to low levels of lead, which may contribute to behavioral problems, learning
deficits, and lowered Intelligence Q uotient (IQ).1

- 4 1.6 PUBLIC COMMENT AND S TAKEHOLD ER P ARTICIPATION

1.6.1 Stakeholder Meetings

The TCEQ held a lead stakeholder m eeting to discuss concepts for potential control strategies

for the Collin C ounty lead nonattainment area and to present an overview of the SIP development process. The meeting was held at the City of Frisco Council Chambe rs on January

19 , 2011. TCEQ staff from the Toxicology

, Air Permits, and Air Quality Divisions presented

information

. Staff was also on hand to answer questions. Staff presented stakeholders with an overview of the health effects of lead, an update on the 2008 lead NAAQS and the associated SIP

revision , an overview of the role of modeling in demonstrat ing attainment, and a draft list of potential control strategies. The presentat ion and additional information about t he lead

stakeholder meeting can be found at the Lead Stakeholder Group Web page ( http://www.tceq.texas.gov/airquality/sip/stakeholders/ pb_stakeholder ).

1.6.2 Public Hearings and Comment Information

The commission will hold a public hearing for the proposed 2011 Collin County Attainment

Demonstration SIP Revision for the 2008 L ead NAAQS , which includes Agreed Order 2011

- 0521

- MIS, at the following time and location:

Table 1

- 2 : Public Hearing Information

City Date Time

Frisco Location

July 28, 2011 6:00 PM Frisco City Council Chambers

6101 Frisco Square Boulevard

Frisco, TX 75034

The public comment period will open on June 24, 2011, and close on August 8 , 2011. Written comments will be accepted via mail, fax, or through the eComments system. All comments

should reference the “ 2011 Collin County Attainment Demonstration SIP Revision for

the 2008 L ead NAAQS ” and Project Number 2011

- 001

- SIP

- NR . Comments may be submitted to C. Holly Brightwell, MC 206, State Implementation Plan Team, Chief Engineer’s Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas

, 78711

- 3087 or faxed to (512) 239

- 5687. Electronic comments may be submitted through the

eComments system ( http://www5.tceq.texas.gov/rules/ecomments ) . File size restrictions may apply to comments being submitted via the eComments system. Comme nts must be received by

close of business August 8 , 2011.

1.7 SOCIAL AND ECONOMIC CONSIDERATIONS

No significant fiscal implications are anticipated for the TCEQ or other uni ts of state or local governments as a result of administration or enforcement of proposed Agreed Order 2011

- 0521

- MIS

. Because Exide is the sole source contributing to the nonattainment area, all controls to reach attainment will be borne by this source. As such, a ny economic impacts will be limited to the single lead source associated with this SIP revision

. The proposed Agreed Order is expected to have significant fiscal impact to Exide. The citizens of a portion of Collin County will benefit

from reduced exposure to ambient lead emissions.

1.8 FISCAL AND MA NPOWER

The TCEQ has determined that its fiscal and manpower resources are adequate and will not b e adversely affected through implementation of this plan.2

- 1 CHAPTER 2: EMISSIONS INVENTORY

2.1 INTRODUCTION

The Federal Clean Air Act

, §172(c)(3) require s the development of emissions inventories (EI) for

nonattainment areas. The Texas Commission on Environmental Quality (TCEQ) maintains a
point source EI with up

- to

- date information on major lead sources

. The EI identifies the types of emissions sources present in an area, the amount of each pollutant emitted, and the types of

process es and control devices employed at each plant or source category.

On N ovember 22 , 2010, the Environmental Protection Agency ( EPA ) designated a portion of Collin County, located in Frisco, Texas, as a lead nonattainment area, effective December 31, 2010 (75 Federal Register [FR] 71033). This nonattainment area surrounds Exide Technologies ’ (Exide) lead battery recycling plant

, a point source that submits annual emissions inventory data to the TCEQ. This chapter discusses general EI development for the point source category.

Contributions from non

- point sources were found to be insignificant. See section 2.3 Other Source Categories

2.2 POINT SOURCES for more information about emissions from non

- point source categories.

2.2.1 Emissions Inventory Development

Stationary point source emissions data are collected annually from sites that meet the reporting requirements of 30 Texa s Administrative Code §101.10. To collect the data, the TCEQ sends emissions inventory questionnaires (EIQ) to all sites identified as meet ing the reporting
requirements. Companies are required to report emissions data and to provide samples of

calculations us ed to determine the emissions. Information characterizing the process equipment, the abatement units, and the emi ssion points is also required. All data submitted in the EIQ are reviewed for quality assurance purposes and then stored in the State of Texas Air Reporting System database.

2.2.2 Updated 2010 Emissions Inventory

The TCEQ requested that Exide submit an expedited 2010 lead emissions inventory for all lead

emitting sources located at the company’s battery re cycling plant in Frisco, Texas. Exide submitted the 2010 lead emissions inventory data to the TCEQ on February 24, 2011

. Total reported lead emissions for 2010 are 1.09 tons per year. No other lead

- emitting point sources

have been identified in the lead no nattainment area.

The 2010 lead emissions inventory that Exide submitted on February 24, 2011 , is reproduced in Appendix C : Annual Emissions Inventory Update for Exide Technologies’ Frisco Lead Battery Recycling Plant

2.3 OTHER SOURCE CATEGOR IES .

According to the Air Emissions Repo rting Requirements (73 FR 76539 ), only annual point source emissions are required to be reported to EPA for the 2010 inventory year . Since the next triennial reporting year is 2011, the mobile and area source periodic emissions inventories were not developed for 2010. However, a review of 2008 data indicated an insignificant contribution of lead emissions (less than 0.1%) from these n on

- point sources. Therefore, the point source category is the only inventory category developed for the inventory year as Exide Technologies’ battery recycling plant in Frisco is the only point source reporting lead emissions in the

nonattainment area.3

- 1 CHAPTER 3: AIR DISPERSION MODEL ING

3.1 INTRODUCTION

Two dispersion modeling analyses were performed for the 2011 Collin County Attainment

Demonstration S tate I mplementation Plan (SIP) R evision for the 2008 Lead National Am bient Air Quality Standard (NAAQS) . One was an analysis of current conditions (base case). The other analysis examined the potential effectiveness of proposed emission controls (future case).

The base case evaluated a reasonable estimate of maximum actual emissions to determine the

sources that contribute most to the highest predicted concentrations. This determination helps identify the sources that may contribute most to actual monitored concentrations. The sources identified as likely contributors to pr edicted maximum concentrations are targeted in the

propos ed Agreed Order 2011

- 0521

- MIS that is associated with this proposed SIP revision

.

The future case evaluated control strateg ies listed in section 4.4 New Control Measures

3.2 MODELING APPROACH of this proposed SIP revisio n and described in Agreed Order 2011

- 0521

- MIS between the Texas Commission on Environmental Quality (TCEQ) and Exide Technologies (Exide). Dispersion modeling was used to validate that the proposed control strateg ies will bring the Collin County

lead nonat tainment area into compliance with the 2008 lead National Ambient Air Quality Standard (NAAQS).

The dispersion modeling analysis was performed using the American Meteorological Society/Environmental Protection Agency Regulatory Model (AER MOD) modeling system. There are two input data processors that are regulatory components of the AERMOD modeling system: AERMET, a meteorological data preprocessor that incorporates air dispersion based on planetary boundary layer turbulence structure and s caling concepts, and AERMAP, a terrain data preprocessor that incorporates complex terrain using United States Geological Survey (USGS) Digital Elevation Data. The Building Profile Input Program for Plume Rise Model Enhancements (BPIPPRM), a multi

- building dimensions program incorporating the good engineering practice (GEP) technical procedures for PRIME applications was also used.

Both the base and future case analyses used identical model programs, model settings, meteorological data, downwash data, and r eceptor grids. The selections made for these analyses

are summarized below.

**•** AERMOD (Version 09292) was used with default regulatory settings. Since the current version of AERMOD is not capable of calculating rolling three

- month average concentrations, the EPA post

- processor LeadPost was used. The input values to LeadPost are monthly average values at each recep tor in the POSTFILE output format from AERMOD.

**•** AERMET ( V ersion B10300) was used to process meteorological data for the period 2006 through 2010.

**•** Downwash parameters were generated using BPIP PRM ( Version 04274). Building and point

source locations were derived from global positioning system (GPS) measurements by TCEQ regional staff and validated by TCEQ Air Permits staff using aerial photography.

**•** The receptor grid used in the modeling analyses consisted of receptors with 100 meter spacing and extended a pproximately 3 kilometers (km) from the Exide site property line in all directions. Discrete receptors were used for the locations of the existing ambient air
monitoring stations.

**•** Terrain elevations within the modeling domain were determined using AERMAP ( Version 09040). The input data used for this analysis were USGS seamless data covering the3

- 2 following digital elevation models (DEMs): Little Elm, Frisco, Lewisville East, and Hebron

data sets.

3.2.1 Meteorology for Base Case and Future Case

In order to generate meteorological input data for use with AERMOD, surface characteristics (Bowen ratio, noontime albedo, and surface roughness length) of the modeling domain must b e obtained for input for AERMET. Values for Bowen ratio and surface roughness length for the

mo deling domain were calculated using the methodology proposed by the Alaska Department of Environmental Conservation (ADEC) described in ADEC Guidance re AERMET Geometric
Means, How to Calculate the Geometric Mean Bowen Ratio and the Inverse

- Distance Weight ed Geometric Mean Surface Roughness Length in Alaska

, 1

The 2001 NLCD was used rather than the 1992 NLCD due to the rapid growth of the Frisco area.
From Un ited States Census Bureau data, the 1990 population of Fri sco was less than 10,000, the

2000 population was over 30,000 , and the 2010 population was over 116, 000 . For this reason

, the 1992 NLCD was deemed not representative of current land c over characteristics. The 2001 NLCD is the most recent available dataset, so it was used for this modeling analysis. with input of land cover data from the USGS National Land Cover Database (NLCD) 2001. The ADEC guidance provided an equivalent calculation method to the surface characteristic pre

- processor program
AER SURFACE (Version 08009), which requires the input of land cover data from the USGS NLCD 1992. The ADEC guidance is for use with land cover data other than the 1992 NLCD.

Using the 1992 NLCD classifications obtained from the AERSURFACE User’s Guide 2 , land cover data from 2001 were reclassified to reasonably e quivalent 1992 NLCD classifications using documentation from the NLCD 1992/2001 Retrofit Land Cover Change Product 3

Meteorological raw input data were used with generalized surface characteristics of the application site and processed with AERMET (Version B10300). This beta version was obtained

from the United States Environmental Prot ection Agency (EPA) Region 6. This version of AERMET integrates one

- minute Automated Surface Observing System (ASOS) wind data with Integrated Surface Hourly Data (ISHD) using the EPA’s AERMINUTE program. ISHD and one

minute ASOS wind data were obtained fr om the National Climactic Data Center (NCDC). The upper air data was obtained from the National Oceanic Atmospheric Administration Earth System Research Laboratory. . Representative Bowen ratio and surface roughness length values were calculated using the reclassified 2001 NLCD with the ADEC guidance. The noontime albedo value was calculated using the reclassified 2001 NLCD for all land classif ications within a 10 km square, as specified by the AERSURFACE User’s Guide, surrounding the Exide site. The Bowen ratio calculated was 0.76, surface roughness was 0 .234 meters, and albedo was 0.174.

Meteorological data from 2006 through 2010 from the Dallas

- Fort Worth surface station (Sta tion # 03927) and the Fort Worth upper air station (Station # 03990) were used in these analyse s. Missing data from the Dallas

- Fort Worth surface station were replaced with available 2006 through 2010 data from the McKinney Airport surface station (Station # 53914). The McKinney Airport was selected because it is the nearest National Weather Service (NWS) station to the lead nonattainment area. The McKinney Airport ISHD and one

- minu te ASOS wind data were processed in conjunction with Fort Worth upper air da ta using AERMET. Any hours that

conta ined missing data in the Dallas

- Fort Worth input file were replaced with the corresponding hourly data in the McKinney Airport input file when available. Table 3

- 1: Missing and Calm Hours in Meteorological Data lists the number of hours with missing and filled data. A “ calm ” is defined as a reporte d wind speed less than three knots.3

- 3 Table 3

- 1 : Missing and Calm Hours in Meteorological Data

Year Total

Hours Missing Hours

Bef ore Fill Missing Hours

After Fill Calm Hours

Before Fill

2006 Calm Hours After

Fill

8760 202 166 28 29

2007 8760 314 294 37 39

2008 8784 211 183 117 119

2009 8760 95 83 19 20

2010 8760 62 42 63 63

3.2.2 Meteorology Sensitivity Analysis

A sensitivity analysis was performed using the base case emissions with unfilled and filled meteorological input data. The rolling 3

- month average lead concentrations were compared receptor by receptor. At the location of the highest predicted concentratio n, the difference in concentration was 0.07%. For all receptors within 1 km of the Exide site, the difference was less than 2% except for five receptors. At those five receptors

, the difference was less than 2.5%. Due to the small number of missing hours o f data, small number of hours with calms compared to

the total number of hours , the highest predicted concentration being at or near the site property line, and the rolling three

- month averaging time for predicted concentrations, additional filling

of met eorological data would not significantly impact the modeling results.

3.3 BASE CASE ANALYSIS

The base case analysis compared model ed predicted rolling three

- month, monthly, and 24

- hour average concentrations to monitored concentrations during the same period. The modeled base case was a reasonable attempt to replicate actual conditions. The purpose of modeling actual conditions was to determine if all sources were accounted for and appropriately characterized in the modeling. If all sources were accounted for a nd characterized, the modeling results should reasonably agree qualitatively with the monitoring data. Qualitative agreement would not be exact agreement between modeled and monitored concentrations in time and space but would represent similarity in conce ntration trends over time and dispersion patterns in a general area. Once the current actual conditions have been sufficiently replicated , the effectiveness of the control strategies can be estimated through the future case analysis.

3.3.1 Base Case Emissions In ventory

3.3.1.1

Sources 18, 21, 22, 23, 37, 38, 39, 45, and 48, authorized by Exide P ermit 1147A, are stacks that were characterized as point sources in the model . Reference Table 3

- 2: Source Characterizations and Emission Rates

Exide Source Description List

E missions from s ources 10, 35, 36, 41, 42, 43, 44, 52, and 53, also authorized by Exide P ermit
1147A, are all fugitive in nature and were characterized as area sources. Fugitive emissions sources are those emissions that are not emitted to the atmosphere th rough a vent, stack, or discrete emission point. The dimensions of the sources are representative of the areas where the
emissions are genera ted. The height of release for Exide s ources 10, 35, 36, 44, and 52 was based , for a list of emission points referenced in this proposed SIP revision. The actual height and diameter for each source was modeled. The stack exit temperature and velocity for each source was based on stack test data provided by Exide for each stack. The

emiss ion rates modeled were the highest hourly emission rate from the mos t recent stack test.

Stack test

- based exit temperatures, velocities, and emission rates were used for the base case analysis because they are representative of actual routine operations.3

- 4 on the height where the emissions esc ape a structure. The release height for s ources Exide 41, 42, and 43 (vehicle traffic) was set to 1 meter, which is a reasonable height for road generated

em issions. The release height of s ource 53 was the height of the conveyance system to the blast

furna ce.

In order to s implify the modeling analysis, Exide s ources 10 and 35 were combined. The modeling analysis used for the lead nonattainment area designation (de signation modeling)

shows that s ource 10 has a higher contribution than s ource 35 at the locati on of the maximum predicted concentration. The combined emissions from both sources were r epresented as coming from only s ource 10. Sources 41, 42, and 43 were also combined. The d esignation modeling shows that s ource 4 1 has a higher contribution than s our ces 42 or 43 at the location of the maximum predicted concentration. The combined emissions from all three sources were

r epresented as coming from only s ource 41. A modeling analysis is considered more

conservative when all emissions are assumed to come fr om one source with the highest predicted concentration rather than apportioned to multiple sources.

Sources 11, 12, 13, 14, 15, 16, 17, 24, 25, and 26, authorized by Exide P ermit 3048A , are stacks

that were characterized as point sources. The actual height and diameter for each source was modeled. The stack exit temperature and velocity for each source was based on stack test data for each stack. The emission rates modeled were the highest hourly emission from the most

recent stack test. The rationale for u sing the stack test results for stack exit temperatures,
velocities, and emission rates was the sam e as for sources authorized by Exide P ermit 1147A.

Emissions from s ources 27 and 28, also authorized by Exide P ermit 3048A, are all fugitive in nature and were characterized as area sources. The dimensions of the sources are representative

of the areas w h ere the emissions are genera ted. The height of release for s ources 27 and 28 was based on the height where the emissions escape a structure.3

- 5 Table 3

- 2 : Exide Source Description List

Emission Point

Number

10 Source Name

Furnace Fugitives

11 Oxide Reactor No. 3 Baghouse Stack

12 Oxide Reactor No. 2 Baghouse Stack

13 Oxide Reactor No. 1 Baghouse Stack

14 Oxide Hygiene Baghouse Stack (MELTPOT1, MELTPOT2, MELTPOT3)

15 North Hammerhill Baghouse Stack

16 Oxide Reactor No. 4 Baghouse Stack

17 South Hammerhill Baghouse Stack

18 Hard Lead Ventilation Baghouse Stack

21 Soft Lead Ventilation Baghouse Stack

22 Specialty Alloy Baghouse Stack

23 Refining Building Vacuum Stack

24 Oxide Reactor No. 5 Baghouse Stack

25 Oxide Reactor No. 6 Baghouse Stack

26 Oxide Reactor No. 7 Baghouse Stack

27 West Truck Loading Fugitives

28 East Truck Loading Fugitives

35 Furnace Fugitives

36 Refining/Casting

37 Reverbatory/Blast Furnaces Fugitives Baghouse Stack

38 Reverbatory/Blast Furnaces Metallurgical Scrubber Stack

39 Slag Fixation Baghouse Stack

41 Vehicle Traffic

42 Vehicle Traffic

43 Vehicle Traffic

44 Raw Material Storage

45 Raw Material Storage/Shredder Baghouse Stack

48 Battery Breaker Scrubber Stack

52 Slag Handling

53 Material Handling

999 Battery Breaker Operation

3.3.1.2

In comparing monitoring data to modeling results considering only the sources authorized by

Exide P ermits 1147A and 3048A, there was a disparity between some actual and predicted concentrations. The actual concentrations were significantly higher than thos e predicted given certain meteorological conditions. The commission concluded that a source or sources were not accounted for in the modeling. Based on the review and analysis of actual and predicted 24

- hour concentrations, there appeared to be an unaccoun ted source to the south

- southeast (SSE) of the Frisco Eubanks monitor ( Air Quality System Identification [AQS ID ] 480850009 ) . When winds Other Sources3

- 6 were blowing from the SSE, the Frisco Eubanks monitor tended to record concentrations significantly higher (one order o f magnitude higher) than the other two existing monitors which are located northeast and southeast of the Frisco Eubanks monitor. In addition, higher wind speeds from the SSE tended to result in higher monitored concentrations.

Exide management informed TC EQ staff that the unaccounted source could be the fugitive emissions from the battery breaking operation . The fugitive emissions from the battery breaking operations for the lead battery recycling industry were previously believed to be negligible due to

t he large amount of liquid in the batteries suppressing particulate emissions. However, ambient air monitoring conducted at the Exide Technologies s ite in Vernon, California

, show t hat emissions from the battery breaker o peration provided to the TCEQ by Exide were a large

contributor to monitored concentrations.

Monitoring data from Exid e’s Frisco , Texas

, and Vernon , California

, sites was used to dev elop an emission rate from the battery breaker o peration for the base case. Data fr om three monitored samples for each site were considered. The data consisted of the 24

- hour average monitored

concentration of lead and 1

- hour average wind speeds. All six sample days experienced winds predominantly bl owing from the battery breaker o perati on to the monitor. Winds during a ll six sample days were high enough that atmospheric stability was assumed to be neutral.

The SCREEN3 (version 96043) dispersion screening model was used to estimate the emission rate necessary to result in the monitored co ncentration given the distance from the operation to

the monitor, wind speed, and neutral stability for that day. The source was represented as an area source the size of the battery breaker operation for the appropriate site. The emission rates in pounds per hour (lb/hr) were converted to an emissions flux in pounds per hour per square meter (lb/hr•m 2 ). The six data points were plotted as emission flux (lb/hr × m 2 ) versus wind speed in miles per hour (mph). A power series correlation was performed on the s ix data points. The resulting equation to estimate emissions was emission flux = 2.0 × 10

- 6 × (wind speed) 1.9822

. The correlation coefficient (R 2 ) value for the correlation was 0.9807 which suggests a strong

correlation. An R 2

The base case modeling was performed again considering the emissions from the battery breaker operation. The source (999) was represented as an area source with dimensions representative of the operation. Since the emissions from this source were assumed to be wind generated, wind category scalars were used in the modeling to account for this behavior. The

scalar values were determined from the equation emission flux = 2.0 × 10 value of 1 would denote a per fect correlation

.

- 6 × (wind speed) 1.9822

3.3.1.3 . The scalar values for each upper bound wind speed in meters per second (m/sec) were 1.00 for
1.54 m/sec, 4.03 for 3.09 m/sec, 11.14 for 5.14 m/sec , 28.56 for 8.24 m/sec, and 49.18 for 10

m/sec.

The largest nearby source of lead emissions is app roximately 50 km from the Exide site with annual reported emissions approximately 10% of the an nual emissions reported by Exide . Due to the great distance to the Exide site and the small reported emission rate , no other sources of lead emissions would have a significant contribution near the Exide site or the modeling domain used for this analysis. Background Sources

3.3.2 Source Input Parameters

Table 3

- 3: Base Ca se Point Source Parameters contains input parameters for all point sources

modeled for the base case. Table 3

- 4 : Base Case Area Source Parameters contains input parameters for all area sources modeled for the base case. The total annual lead emissions3

- 7 repr esented is 4 .39 tpy

, based on a representative worst case 24

- hour period. The modeling

assumes that emission rates are continuous 24 hours a day

, 365 days a year. Because Exide’s

proc ess rate varies from day to day, the continuous emissions assumption pred icts a higher ambient concentration than would be expected in reality.3

- 8 Table 3

- 3 : Base Case Point Source Parameters

Source

ID Easting

(meters) Northing

(meters) Elevation

(meters) Height

(meters) Temp

(Kelvin) Velocity

(m eters

per

second ) Diameter

(meters)

11 Emission

Rate ( pound

per hour )

702713 3668797 194.89 16.76 369 12.04 0.3048 0.0069

12 702713 3668794 194.87 16.76 369 8.50 0.3048 0.0134

13 702713 3668792 194.85 15.85 391 13.17 0.3048 0.0015

14 702721 3668793 194.95 16.76 328 27.96 0.5334 0.0061

15 702725 3668808 195.17 16.76 350 14.17 0.3810 0.0031

16 702718 3668803 195 17.37 369 13.47 0.2530 0.0030

17 702729 3668780 194.88 16.76 355 14.02 0.3810 0.0058

18 702628 3668768 193.7 30.63 313 4.98 1.6154 0.0400

21 702627 3668739 193.59 31.24 311 18.08 1.5210 0.0600

22 702686 3668804 194.63 22.86 304 15.05 0.8108 0.0200

23 702637 3668765 193.77 7.70 351 14.19 0.1778 0.0004

24 702722 3668783 194.85 16.46 369 11.49 0.3810 0.0010

25 702722 3668778 194.8 16.46 358 9.45 0.3810 0.0015

26 702736 3668783 194.97 9.14 355 11.58 0.1524 0.0015

37 702683 3668810 194.63 22.86 309 19.15 1.6764 0.0500

38 702620 3668772 193.65 50.29 315 15.94 1.3716 0.0952

39 702546 3668731 193.17 19.10 0 * 45.00 0.4877 0.0530

45 702623 3668714 193.5 32.16 303 12.92 1.8044 0.0700

48 702585 3668771 193.38 15.77 0 * 12.28 1.0097 0.0025

* Denotes ambient temperature3

- 9 Table 3

- 4 : Base Case Area Source Parameters

Source

ID Easting

(meters) Northing

(meters) Elevation

(meters) Height

(meters) East

- West

Length

(meters) North

- South

Length

(meters) Rotation

Angle

10 Emission

Rate

( pounds per

hour )

702643 3668771 193.87 4.57 28.956 24.384

- 2 0.0800

27 702734 3668768 194.80 4.57 0.914 0.914 0 0.0010

28 702756 3668782 195.40 4.57 0.914 0.914 0 0.0010

35 702654 3668740 193.79 4.57 22.860 30.480

- 2 0.0000

36 702646 3668755 193.80 4.57 32.004 15.240

- 2 0.0100

41 702518 3668769 193.03 1.00 94.488 21.336 40 0.0388

42 702625 3668693 193.42 0.30 80.772 44.196

- 2 0.0000

43 702703 3668745 194.26 0.30 62.484 39.624

- 2 0.0000

44 702591 3668760 193.42 3.99 24.384 41.148

- 2 0.0300

52 702632 3668766 193.72 4.57 21.336 16.764

- 2 0.0100

53 702616 3668762 193.58 1.83 16.764 19.812

- 2 0.1300

999 702555 3668760 193.21 1.00 40 40

- 2 0.03803

- 10 3.3.3 Base Case Modeling Results

Table 3

- 5: Base Case Source Contribution at Location of Maximum Predicted Concentration lists the contributions of each source at the location of the maximum rolling three

- month predicted concentration in microgram per cubic meter (μg/m 3 ). These results suggest which sources require controls and to what extent in order for the Exide Frisco S ite to operate in compliance with the 2008 lead NAAQS. The sources with the highest contributions are 10, 41,
44, 53, and 999 . The contribution of these five sources at the location of the maximum predicted concentration is 1.2922 μg/m 3 . The contribution f rom all other sources is 0.1493 μg/m 3

The post

- processor LeadPost reports results were rounded to three decimal places. In order to display the rolling three

- month concentrations to five decimal places, output files from AERMOD using the MAXIFILE option f or monthly averages with a reporting threshold of 0.00001 μg/m .

3 were generated. The three

- month rolling averages to five decimal places were calculated from the monthly averages reported by the MAXIFILE output.3

- 11 Table 3

- 5 : Base Case Source Contribution at Location of Maximum Predicted

Concentration

Source ID Source Contribution
(μg/m3)

10 Source Contribution

Percent of Maximum

0.19758 13.71%

11 0.00375 0.26%

12 0.00789 0.55%

13 0.00084 0.06%

14 0.00219 0.15%

15 0.00141 0.10%

16 0.00157 0.11%

17 0.00274 0.19%

18 0.00878 0.61%

21 0.00794 0.55%

22 0.00616 0.43%

23 0.00039 0.03%

24 0.00052 0.04%

25 0.00081 0.06%

26 0.00126 0.09%

27 0.00178 0.12%

28 0.00163 0.11%

36 0.02303 1.60%

37 0.00781 0.54%

38 0.00517 0.36%

39 0.02714 1.88%

41 0.08894 6.17%

44 0.07487 5.19%

45 0.01068 0.74%

48 0.00165 0.11%

52 0.02412 1.67%

53 0.32835 22.78%

999 0.60249 41.80%

ALL 1.44149 100.00%

3.4 FUTURE CASE ANALYSIS

The future case modeling analysis evaluated the proposed emission controls that demonstrate attainment of the 2008 lead NAAQS in the current lead nonattainment area surrounding the Exide site. The emission controls represented in the future case analysis a re:3

- 12 **•** f ull y enclose under negative pressure of the b attery b reaker o peration and raw material

storage area (sources 44 and 999) . This change will eliminate fugitive emissions from these

area s. The collected emissions wil l be routed to a new baghouse (s ource 10A and 35A ) ;

**•** f ull y enclose under negative pressure of the b last f urnace and r everberatory f urnace areas ( s ources 10 and 35) . This change will eliminate fugitive emissions from these areas. The

collected emissions from the blast furnace area wil l be routed to a new baghouse (s ource 10A). The collected emissions from the reverberatory furnace area wil l be routed to a new baghous e (s ource 35A) . In addition, the emissions generated in the reverberatory furnace area will be reduced by replacing the hydraulic ra m loader with a rotary screw ;

**•** f ully enclose, under negative pressure, the slag handling area, material handling area, and refining/casting area (sources 52, 53, and 36) . This change will eliminate the fugitive

emissions from these areas. The collected emis sions from the slag handling and material handling areas wil l be routed to a new baghouse (s ource 10A). The collected emissions from the refining/casting area wil l be routed to a new baghouse (s ource 35A);

**•** r elocate the slag treatment building and replace me nt of the ex isting slag fixation baghouse (s ource 39) with a new baghouse. The new baghouse will be fitted with polytetrafluoroethylene (PTFE) membrane media and improved setting design. This change

will reduce emissions due to improved emissions collectio n; and

**•** r eroute the truck traffic (s ources 41, 42, and 43) . This change will redu ce emissions from

truck traffic due to the route not going through the process areas . The emissions from the new route (s ource ROA D) will replace emissions from s ources 41, 42 , and 43.

Additional emission control measures not taken into consideration for the future case analysis

are:

**•** r eplacement of bag media, with polytetrafluoroethylene (PTFE) membrane media , in

s ources 18, 22, 23, and 37. This change w ould reduce emissions fr om these sources due to improved collection of particulate matter;

**•** r eplacement of tube sheeting in s ources 18, 21, 22, 23, 37, and 39. This change would reduce emissions from these sources due improved c ollection of particulate matter; and

**•** i nstallation of secondary high efficiency particulate air (HEPA) filtration on all baghouses that receive lead emissions (sources 11 through 18, 21 through26, 37, and 39) except for the reverbatory and blast furnace baghouse (source 38).

The reduction in emissions due to the tube sheeting and new baghouse media has not been quantified due to engineering design specifications not being available. Though a reduction in

emissions is expected, no reduction in emissions has been attributed to t hese emission control

measures.

3.4.1 Future Case Emissions Inventory

For the future case, all bagho use stacks associated with the soft lead and hard lead production (s ources 18, 21, 22, 23, 37, 38, 39, 45, and 48) were represented exactly as they were for the base case with the exception of the emission rates. The emission rates modeled were based on stack

tests data , the production rate at the time of the stack tests, and the maximum permitted daily production of 400 tons of finished lead product. Details of the stack test are contained in Table

3

- 6 : Stack Test Details from Baghouses Covered Under Permit 1147A

.3

- 13 Table 3

- 6 : Stack Test Details from Baghouses Covered Under Exide Permit 1147A

Source

ID Mode led

Rate

( pound

per hour ) Stack

Test Date Production

( tons per day ) Corrected

Max. Rate

( pound per

hour ) Avg. Test

Rate ( pound

per hour ) Test Rate

( pound per

hour )

18 0.0275 2003 226 0.0160 0.0090 0.0116

18 0.0275 2003 226 0.0160 0.0090 0.0113

18 0.0275 2003 226 0.0160 0.0090 0.0042

18 0.0275 2005 221 0.0198 0.0110 0.0118

18 0.0275 2005 221 0.0198 0.0110 0.0105

18 0.0275 2005 221 0.0198 0.0110 0.0106

18 0.0275 2007 221 0.0225 0.0124 0.0070

18 0.0275 2007 221 0.0225 0.0124 0.0115

18 0.0275 2007 221 0.0124 0.0188

18 0.0275 2009 230 0.0519 0.0298 0.0435

18 0.0275 2009 230 0.0519 0.0298 0.0256

18 0.0275 2009 230 0.0519 0.0298 0.0203

21 0.1743 2003 235 0.7730 0.4542 0.3800

21 0.1743 2003 235 0.7730 0.4542 0.4875

21 0.1743 2003 235 0.7730 0.4542 0.4950

21 0.1743 2005 216 0.0340 0.0184 0.0141

21 0.1743 2005 216 0.0340 0.0184 0.0147

21 0.1743 2005 216 0.0340 0.0184 0.0263

21 0.1743 2007 216 0.4074 0.2200 0.2100

21 0.1743 2007 216 0.4074 0.2200 0.2300

21 0.1743 2009 235 0.0815 0.0479 0.0359

21 0.1743 2009 235 0.0815 0.0479 0.0566

21 0.1743 2009 235 0.0815 0.0479 0.0511

22 0.0086 2003 220 0.0101 0.0056 0.0062

22 0.0086 2003 220 0.0101 0.0056 0.0047

22 0.0086 2003 220 0.0101 0.0056 0.0058

22 0.0086 2005 226 0.0062 0.0035 0.0039

22 0.0086 2005 226 0.0062 0.0035 0.0037

22 0.0086 2005 226 0.0062 0.0035 0.0029

22 0.0086 2007 226 0.0077 0.0043 0.0040

22 0.0086 2007 226 0.0077 0.0043 0.0050

22 0.0086 2007 226 0.0077 0.0043 0.0040

22 0.0086 2009 236 0.0105 0.0062 0.0161

22 0.0086 2009 236 0.0105 0.0062 0.0020

22 0.0086 2009 236 0.0105 0.0062 0.00043

- 14 Source

ID Mode led

Rate

( pound

per hour ) Stack

Test Date Production

( tons per day ) Corrected

Max. Rate

( pound per

hour ) Avg. Test

Rate ( pound

per hour ) Test Rate

( pound per

hour )

37 0.0450 2003 235 0.0323 0.0190 0.0199

37 0.0450 2003 235 0.0323 0.0190 0.0169

37 0.0450 2003 235 0.0323 0.0190 0.0202

37 0.0450 2005 221 0.0594 0.0328 0.0234

37 0.0450 2005 221 0.0594 0.0328 0.0370

37 0.0450 2005 221 0.0594 0.0328 0.0380

37 0.0450 2007 221 0.0761 0.0421 0.0541

37 0.0450 2007 221 0.0761 0.0421 0.0350

37 0.0450 2007 221 0.0761 0.0421 0.0372

37 0.0450 2009 236 0.0122 0.0072 0.0098

37 0.0450 2009 236 0.0122 0.0072 0.0026

37 0.0450 2009 236 0.0122 0.0072 0.0093

38 0.1005 2003 230* 0.1658 0.0953 0.0920

38 0.1005 2003 230* 0.1658 0.0953 0.0820

38 0.1005 2003 230* 0.1658 0.0953 0.1120

38 0.1005 2005 230* 0.0151 0.0087 0.0030

38 0.1005 2005 230* 0.0151 0.0087 0.0030

38 0.1005 2005 230* 0.0151 0.0087 0.0200

38 0.1005 2007 243 0.1500 0.0911 0.0695

38 0.1005 2007 243 0.1500 0.0911 0.0455

38 0.1005 2007 243 0.1500 0.0911 0.1584

38 0.1005 2009 223 0.0712 0.0397 0.0338

38 0.1005 2009 223 0.0712 0.0397 0.0210

38 0.1005 2009 223 0.0712 0.0397 0.0642

45 0.0688 2003 220 0.0944 0.0519 0.0523

45 0.0688 2003 220 0.0944 0.0519 0.0536

45 0.0688 2003 220 0.0944 0.0519 0.0498

45 0.0688 2005 223 0.0676 0.0377 0.0473

45 0.0688 2005 223 0.0676 0.0377 0.0353

45 0.0688 2005 223 0.0676 0.0377 0.0305

45 0.0688 2007 223 0.0533 0.0297 0.0357

45 0.0688 2007 223 0.0533 0.0297 0.0331

45 0.0688 2007 223 0.0533 0.0297 0.0203

45 0.0688 2009 347 0.0599 0.0519 0.0459

45 0.0688 2009 347 0.0599 0.0519 0.0379

45 0.0688 2009 347 0.0599 0.0519 0.07203

- 15 Source

ID Mode led

Rate

( pound

per hour ) Stack

Test Date Production

( tons per day ) Corrected

Max. Rate

( pound per

hour ) Avg. Test

Rate ( pound

per hour ) Test Rate

( pound per

hour )

23 0.0006 2003 226 0.0006 0.0004 0.0004

23 0.0006 2003 226 0.0006 0.0004 0.0003

23 0.0006 2003 226 0.0006 0.0004 0.0004

39 0.0513 2010 230* 0.0513 0.0295 0.0155

39 0.0513 2010 230* 0.0513 0.0295 0.0515

39 0.0513 2010 230* 0.0513 0.0295 0.0216

48 0.0037 2010 230* 0.0037 0.0021 0.0025

48 0.0037 2010 230* 0.0037 0.0021 0.0025

48 0.0037 2010 230* 0.0037 0.0021 0.0013

* Default value due to daily production value not being available

Stack test data from 2003, 2005, 2007, 2009 , and 2010 were considered for s ources 18, 21, 22, 23, 37, 38, 39, 45, and 48. The average emission rate for each stack test and the associated daily production on the date of the stack test were used to calculate a maximum 24

- hour emission rate. The average emission rate was multiplied by the maximum permitted daily production divided by actual daily production on the date of the stack test. For example, if the average

emission rate for the stack test was 1.0 lb/hr and the daily production on the day of the stack test was 200 tons, then the value 2.0 lb/hr = (1.0 lb/hr) × (400 tons/200 tons) was used. The emission rate modeled for a source was the average rate for all stack tests.

Production data were not available for all stack tests. A default value of 230 tons was used for all days when the daily production value was not available. The average daily production for days during stack tests was 232 tons, therefore 230 tons is a reasonable value.

For s ource 21, stack tests from 2005, 2007, and 2009 were considered. The data from the 2003 stack tests were not considered as the calculated rates were over a 10 times higher than any other test. Since the 2003 values are so much higher than other tests, they are judged to be anomalies and not indicative of normal operations.

All baghouse stacks associated with the lead oxide reactors (s ources 11, 12, 13, 16, 24, and 25) were represented exactly as they were for the base case with the exception o f the emission rates.

The emission rates modeled were based the stack tests for that source and the maximum permitted hourly production of 2,300 lb/hr of lead oxide. Details of the stack test are contained

in Table 3

- 7

: Stack Test Details from Baghouses Co vered Under Exide Permit 3048A

.3

- 16 Table 3

- 7 : Stack Test Details from Baghouses Covered Under Exide Permit 3048A

Source

ID Modeled

Rate (lb/hr) Stack

Test Date Production

( lb/hr ) Corrected

Max. Rate

(lb/hr) Avg. Test Rate (lb/hr) Test Rate (lb/hr)

14 0.0055 1995 No Data

Available 0.0055 0.0055 0.0061

14 0.0055 1995 No Data

Available 0.0055 0.0055 0.0055

14 0.0055 1995 No Data

Available 0.0055 0.0055 0.0050

26 0.0004 1994 No Data

Available 0.0004 0.0004 0.0004

26 0.0004 1994 No Data

Available 0.0004 0.0004 0.0006

26 0.0004 1994 No Data

Available 0.0004 0.0004 0.0003

13 0.0012 1994 2232 0.0014 0.0014 0.0015

13 0.0012 1994 2232 0.0014 0.0014 0.0013

13 0.0012 1994 2232 0.0014 0.0014 0.0014

13 0.0012 1995 2232* 0.0010 0.0010 0.0010

13 0.0012 1995 2232* 0.0010 0.0010 0.0010

13 0.0012 1995 2232* 0.0010 0.0010 0.0009

12 0.0043 1994 2227 0.0018 0.0017 0.0029

12 0.0043 1994 2227 0.0018 0.0017 0.0012

12 0.0043 1994 2227 0.0018 0.0017 0.0011

12 0.0043 1995 2227* 0.0068 0.0066 0.0134

12 0.0043 1995 2227* 0.0068 0.0066 0.0026

12 0.0043 1995 2227* 0.0068 0.0066 0.0037

11 0.0021 1994 2173 0.0008 0.0007 0.0005

11 0.0021 1994 2173 0.0008 0.0007 0.0006

11 0.0021 1994 2173 0.0008 0.0007 0.0011

11 0.0021 1995 2173* 0.0034 0.0032 0.0069

11 0.0021 1995 2173* 0.0034 0.0032 0.0015

11 0.0021 1995 2173* 0.0034 0.0032 0.0011

16 0.0014 1994 2227 0.0012 0.0012 0.0008

16 0.0014 1994 2227 0.0012 0.0012 0.0015

16 0.0014 1994 2227 0.0012 0.0012 0.0012

16 0.0014 1995 2227* 0.0017 0.0016 0.0030

16 0.0014 1995 2227* 0.0017 0.0016 0.0008

16 0.0014 1995 2227* 0.0017 0.0016 0.00103

- 17 Source

ID Modeled

Rate (lb/hr) Stack

Test Date Production

( lb/hr ) Corrected

Max. Rate

(lb/hr) Avg. Test Rate (lb/hr) Test Rate (lb/hr)

24 0.0017 1994 2214 0.0005 0.0005 0.0003

24 0.0017 1994 2214 0.0005 0.0005 0.0005

24 0.0017 1994 2214 0.0005 0.0005 0.0006

24 0.0017 1995 2214* 0.0030 0.0029 0.0070

24 0.0017 1995 2214* 0.0030 0.0029 0.0006

24 0.0017 1995 2214* 0.0030 0.0029 0.0010

25 0.0010 1994 2192 0.0014 0.0013 0.0015

25 0.0010 1994 2192 0.0014 0.0013 0.0012

25 0.0010 1994 2192 0.0014 0.0013 0.0013

25 0.0010 1995 2192* 0.0007 0.0007 0.0009

25 0.0010 1995 2192* 0.0007 0.0007 0.0005

25 0.0010 1995 2192* 0.0007 0.0007 0.0006

17 0.0017 1994 6639 0.0030 0.0029 0.0058

17 0.0017 1994 6639 0.0030 0.0029 0.0023

17 0.0017 1994 6639 0.0030 0.0029 0.0005

17 0.0017 1995 6639* 0.0005 0.0005 0.0005

17 0.0017 1995 6639* 0.0005 0.0005 0.0007

17 0.0017 1995 6639* 0.0005 0.0005 0.0003

15 0.0025 1994 6460 0.0023 0.0022 0.0015

15 0.0025 1994 6460 0.0023 0.0022 0.0029

15 0.0025 1994 6460 0.0023 0.0022 0.0021

15 0.0025 1995 6460* 0.0027 0.0025 0.0028

15 0.0025 1995 6460* 0.0027 0.0025 0.0031

15 0.0025 1995 6460* 0.0027 0.0025 0.0017

* Default value due to daily production value not being available

The remaining baghouses associat ed with lead oxide production (s ources 14, 15, 17, and 26) were represented exactly as they were for the base case with the exception of the emission rates.

The emission rates modeled were based the stack tests for that source and the maximum permitted hourly production of 6,900 pound pe r hour of lead oxide.

The maximum hourly rates are used for the lead oxide sources rather than a 24

- hour rate because there are only hourly and annual production limits in the existing permit 3048A.

Stack test data from 199 4 and 1995 were considered for s o urces 11, 12, 13, 14, 15, 16, 17, 24, 25,

and 26. The 1994 and 1995 data were the only data available. The average emission rate for each stack test and the associated hourly production on the date of the stack test were used to calculate a maximum hourly emission rate. The average emission rate was multiplied by the maximum permitted hourly production divided by actual hourly production during the stack test. For example, if the average emission rate for the stack test was 1.0 lb/hr and the hourly producti on during the stack test was 1,000 lb/hr, then the value 2.3 lb/hr = (1.0 lb/hr) × (2,3003

- 18 lb/1,000 lb) was used. The emission rate modeled for a source was the average rate for all stack

tests for that source.

Production data were not available for the 19 95 stack tests. The production values for the 1994 stack test were assumed to be typical and were used with the 1995 stack test data.

Emissions from the s ources 27, 28, and ROAD (vehicle traffic) , are all fugitive in nature and

were characterized as area s ources. The dimensions of the sources are representative of the areas were the emissions are generated. The hei ght of release for s ources 27 and 28 is based on the height where the emissions escape a str ucture. The release height for s ource ROAD was set

to 1 meter

, which is a reasonable release height for road generated emissions.

The emission rat e used for s ource 27 was based on a maximum hourly loading rate of 12 tons per hour (tons/hr) of lead oxi de. The emission rate used for s ources 28 was based on a maximum hourly loading rate of 24 tons/hr of lead oxi de. The emission rate used for s ource ROAD was

based on the anticipated number of vehicles.

3.4.2 Background Sources

The largest nearby source of lead emissions is approximately 50 km from the Exide site with annual reported emissions approximately 10% of the annual emissions reported by Exide. Due

to the distance from the Exide site and the small reported emission s , no other sources of lead emissions would have a significant contribution near the Exide site or the modeling domain used for this analysis.

3.4.3 Source Input Parameters

Table 3

- 6: Future Case Point Parameters contains input parameters for all point sources

mod eled for the future case. Table 3

- 7: Future Case Area Source Parameters

, Table 3

- 8 : Future Case AreaPoly Source Parameters

, and Table 3

- 9: Vertices of AreaPoly Source ROAD all contain input parameters for all area sources modeled for the future case. The total annual lead

emi ssions represented is 2.39 tons and is based on a represent ative worst case 24

- hour period. The modeling assumes that emission rates are continuous 24 hours a day

, 365 days a year. In reality

, the process rate varies from day to day.3

- 19 Table 3

- 8 : Future Case Point Parameters

Source ID Easting

(meters) Northing

(meters) Elevation

(meters) Height

(meters) Temp

(Kelvin) Velocity

(meters

per

sec ond ) Diameter

(meters) Emission Rate

( pound per

hour )

11 702713 3668797 194.89 16.76 369 12.04 0.3048 0.0021

12 702713 3668794 194.87 16.76 369 8.50 0.3048 0.0043

13 702713 3668792 194.85 15.85 391 13.17 0.3048 0.0012

14 702721 3668793 194.95 16.76 328 27.96 0.5334 0.0055

15 702725 3668808 195.17 16.76 350 14.17 0.3810 0.0025

16 702718 3668803 195.00 17.37 369 13.47 0.2530 0.0014

17 702729 3668780 194.88 16.76 355 14.02 0.3810 0.0017

18 702628 3668768 193.70 30.63 313 4.98 1.6154 0.0275

21 702627 3668739 193.59 31.24 311 18.08 1.5210 0.1743

22 702686 3668804 194.63 22.86 304 15.05 0.8108 0.0086

23 702637 3668765 193.77 7.70 351 14.19 0.1778 0.0006

24 702722 3668783 194.85 16.46 369 11.49 0.3810 0.0017

25 702722 3668778 194.80 16.46 358 9.45 0.3810 0.0010

26 702736 3668783 194.97 9.14 355 11.58 0.1524 0.0004

37 702683 3668810 194.63 22.86 309 19.15 1.6764 0.0450

38 702620 3668772 193.65 50.29 315 15.94 1.3716 0.1005

39 70265 9 3668833 194.34 30.48 0 * 21.560 0.9144 0.0513

45 702623 3668714 193.50 32.16 303 12.92 1.8044 0.0688

48 702585 3668771 193.38 15.77 0 * 12.28 1.0097 0.0037

10A 70263 6 3668804 193.96 30.48 0* 16.8 2 1.524 0 0.0103

35A 70268 3 3668739 194.00 30.48 0* 19.80 2.1336 0.0238

48A 702618 3668794 193.70 15.77 0 * 12.28 1.524 0 0.0047

* Denotes ambient temperature3

- 20 Table 3

- 9 : Future Case Area Source Parameters

Source ID Easting

(meters) Northing

(meters) Elevation

(meters) Height

(meters) East

- West

Length

(meters) North

- South

Length

(meters) Rotation

Angle Emission

Rate
(lb/hr)

27 702734 3668768 194.80 4.57 0.914 0.914 0 0.0006

28 702756 3668782 195.40 4.57 0.914 0.914 0 0.0013

Table 3

- 10 : Future Case AreaPoly Source Parameters

Source

ID Easting

(meters) Northing

(meters) Elevation

(meters) Height

(meters) Vertices Emission Rate
(lb/hr)

ROAD 70253 2 3668809 193.02 1 .00 9 0.00173

- 21 Table 3

- 11 : Vertices of AreaPoly Source ROAD

Vertex Easting

(meters) Northing

(meters)

1 702532 3668809

2 702807 3668880

3 702811 3668755

4 702867 3668755

5 702865 3668778

6 702830 3668776

7 702825 3668904

8 702527 3668833

9 702532 3668812

3.4.4 Future Case Modeling Results

The maximum predicted three

- month rolling concentration for the future case was 0.147 μg/m 3 (0.14739 μg/m 3 ) . The post

- processor LeadPost reports results were rounded to three decimal

p laces. In order to display the three

- month rolling concentrations to five decimal places, output files from AERMOD using the MAXIFILE option for monthly averages with a reporting threshold of 0.00001 μg/m 3

Since the maximum predicted three

- month rolling concentration is less than 0.15 μg /m were generated. The three

- month rolling averages to five decimal places were calculated from the monthly averages reported by the MAXIFILE output.

3

Table 3

- 10: , attainment of the 2008 lead NAAQS is expected

, based upon implementation of proposed

emission controls.

Future Case Source Contribution at Location of Maximum Predicted Concentration

Table 3

- 12 : Future Case Source Contribution at Location of Maximum Predicted

Concentration lists the contributions of each source at the location of the maximum rolling 3

- month predicted

concentration

.

Source

ID Source Contribution
(μg/m3)

10A Source Contribution

Percent of Maximum

0.00378 2.56%

11 0.00139 0.94%

12 0.00294 1.99%

13 0.00080 0.54%

14 0.00282 1.91%

15 0.00150 1.02%

16 0.00090 0.61%

17 0.00098 0.67%

18 0.00957 6.49%

21 0.04009 27.20%

22 0.00413 2.80%3

- 22 Source

ID Source Contribution
(μg/m3)

23 Source Contribution

Percent of Maximum

0.00052 0.35%

24 0.00105 0.71%

25 0.00062 0.42%

26 0.00032 0.22%

27 0.00059 0.40%

28 0.00134 0.91%

35A 0.00712 4.83%

37 0.01424 9.66%

38 0.00891 6.04%

39 0.01902 12.91%

45 0.01843 12.50%

48 0.00255 1.73%

48A 0.00157 1.07%

ROAD 0.00221 1.50%

ALL 0.14739 100.00%

3.5 REFERENCES



### 1. “ADEC Guidance re AERMET Geometric Means, How to Calculate the Geometric Mean

Bowen Ratio and the Inverse

- Distance Weighted Geometric Mean Surface Roughness Length in Alaska,” Alaska Department of Environmental Conservation, Revised June 17,

2009.



### 2. “AERSURFACE User’s Guide”, EPA

- 454/B

- 08

- 001, U nited States Environmental Protection Agency, Office of Air Quality Planning and Standards, Air Quality Assessment Division, Air Quality Modeling Group, Resear ch Triangle Park, North Carolina, January 2008.



### 3. “NLCD 1992/2001 Retrofit Land Cover Change Product”, website http://www.mrlc.gov/multizone.php, U.S. Department of the Interior, U.S. Geological Survey, February 25, 2008.4

- 1 CHAPTER 4: CONTROL S TRATEGY AND REQUIRED ELEMENTS

4.1 INTRODUCTION

The Collin County nonattainment area for the 2008 lead National Ambient Air Quality Standard (NAAQS) consists of a 1.28 square mile area surrounding the Exide Technologies, Inc. (Exide)

lead

- acid battery recycling operations in Frisco, Texas. Exide is the sole contributor to ambient air lead emissions in the area. In addition to permits 1147A and 3048A held by Exide for the secondary lead smelting and lead oxide operations at the lead

- acid battery recycling facility, the

Texas Commission on Environmental Quality (TCEQ) has made control measures and contingency measures enforceable through agreed orders adopted as part of the 1993 Lead state implementation plan (SIP) for Collin County, the 1999 Collin County Redesignation and

Ma intenance Plan for Lead, and the 2009 Collin County Maintenance Plan for Lead.

As part of this proposed SIP revision, the TCEQ is pursuing Agreed Order 2011

- 0521

- MIS as a means to establish enforceable control measures and operational work practices to red uce lead emissions from point and fugitive lead

- dust sources in support of achieving attainment of the 2008 lead NAAQS by the December 31, 2015, compliance date.

In support of the agreed order and SIP revision

, the TCEQ commissioned third

- party contractor Eastern Research Group, Inc. (ERG) to perform a comprehensive evaluation of air quality control technologies for lead

- acid battery recycling operations with secondary lead smelters and

lead oxide facilities

. On April 2 5, 2011, ERG submitted their report, C omprehensive Evaluation of Air Quality Control Technologies used for Lead

- Acid Battery Recycling ( http://www.tceq.texas.gov/airquality/sip/stakeholders/pb_stakeholder ). The report evaluated available control measures and work practices for the reduction of lead emissions from point sources and fugitive lead

- dust emissions and identified control measure recommendations specific to the source s of lead emissions at the Exide facilities . The TCEQ has analyzed the recommended control technologies and measures in the report and is proposing as part of Agreed Order 2011

- 0521

- MIS those measures that were found to advance attainment as soon as practicable and meet the criteria of r easonably available control technol ogy (RACT) and reasonably available control measures (RACM) . For further information regarding individual control measures please see Appendix D:

This chapter describes existing lead emission control measures in place at Exide, control measures implemented as part of the agreed order associated with this proposed SIP revision, as

well as how Texas is proposing to meet lead nonattain ment area SIP requirements of RACT,

RACM , and contingency measures. Reasonably Available Control Technology and Reasonably Available Control Me asure Analysis

.

4.2 EXISTING CONTROL MEA SURES

30 Texas Administrative Code (TAC) Chapter 113 previously incorporated t he existing federal regulations for control of hazardous air pollutants (HAP) from lead sm elting facilities that

include the National Emission Standards for Hazardous Air Pollutants ( NESHAP ) for secondary

lead smelti ng (40 C ode of Federal regulations [CFR] Part 63, Subpart X). The United States Environmental Protection Agency (EPA ) published a propos ed revision to NESHAP for secondary lead smelting in the May 19, 2011 Federal Register (76 FR 29032)

. In addition , Texas has maintained enforceable controls measures for Exide through a series of agreed orders for the facility. Prior to being operated by Exide, the secondary lead smelter and battery recycling facility in Frisco, Texas, was operated by Gould National Battery, Inc., and by GNB Technologies, Inc (GNB). In 1992, GNB entered into Agreed Board Order 92

- 09(k) with the4

- 2 Texas Air Contro l Board (TACB), a predecessor agency to the TCEQ, and special provisions were included in amendments to Air Quality Permits R

- 1147A and R

- 5466D to assure maintenance of the 1978 lead NAAQS and to resolve notices of violations regarding exceedances of the 1 978 lead
NAAQS.

GNB subsequently amended Air Quality Permits 1147A and issued new permit 3048A to
incorporate provisions in Agreed Board Order 92

- 09(k) (Order 92

- 09k) as permanent and

enforceable control measures. The maximum allowable emission rate of lea d in these permits ensured that lead emissions would not exceed 4.27 tons per year (tpy). In 1993, GNB entered into Agreed Board Order 93

- 12 (Order 93

- 12) with the TACB to establish contingency measures related to the 1993 Lead SIP for Collin County.

As p art of the 1999 Collin County Redesignation and Maintenance Plan for Lead , GNB entered into Agreed Order 99

- 0351

- SIP, which terminated Orders 93

- 12 and 92

- 09(k); however, GNB agreed to continue implementation of these measures, or to implement additional m easures or control technologies proposed by GNB that were judged by the TCEQ executive director to be similarly effective in controlling lead emissions from the plant. Exide acquired the GNB plant in Collin County in 2000.

The state maintained permanence o f the earlier reductions through Agreed Order 2009

- 0071

- MIS, in which Exide agreed to abide by representations made by GNB to continue implementation of the requirements of paragraph eight in Order 92

- 09(k) as incorporated in permits 1147A and 3048A or to implement additional proposed measures or control technologies judged by the executive director to be similarly effective in controlling lead emissions from the plant.

In 2009, Exide entered into Agreed Order 2009

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- MIS with the executive director as pa rt of

the second ten

- year maintenance plan for the 1978 lead NAAQS. As part of that agreed order, Exide agreed to continue implementation of measures previously implemented. Exide also agreed to maintain records for the period of the second ten

- year mainte nance plan (2009 through 2019) and make those records available upon request by the TCEQ or any other air pollution control agency with jurisdiction.

Below is a list of the existing control measures applicable to the Collin County lead

nonattainment a rea u nder Agreed Order 2009

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- MIS :

**•** a ddition of a supplemental ventilation baghouse to the reverberatory and blast furnace metallurgical operations area;

**•** installation of covers over blast furnace bins and water spray system over the bin area;

**•** installation of a baghouse and supporting ventilation and ducting at the raw materials storage building;

**•** installation of a feed dryer and baghouse at the reverberatory furnace charging area to reduce the possibility of reverberatory furnace explosions due to wet feed;

**•** dev elopment and implementation of a detailed site operation and maintenance plan for all site baghouse operations;

**•** installation of a Tri

- bo Flow® System in all baghouse ducts to detect upset emissions;

**•** maintenance of compliance with all emission limits and standard operating procedures for process sources, process fugitive sources, and fugitive dust sources from the National Emissions Standards for Hazardous Air Pollutants from Secondary Lead Smelters under 40 CFR Part 63 Subpart X;

**•** maintenance of records fr om the second (2009) maintenance plan sufficient to demonstrate compliance with control measures and requirements under the Agreed Orders;4

- 3 **•** restrictions on any increase in actual emissions above 4.27 tpy without qualification and approved amendments to p erm its 1147A and 3048A or through a the issuance of a new permit pursuant to 30 TAC Chapter 116, along with executive director approved dispersion modeling demonstrating that such an increase will not cause a violation of the lead NAAQS;

and

**•** continue to main tain all air pollution control and monitoring equipment in good working order and operate it properly during normal operation.

In addition to the above control measures, Agreed Order 2009

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- MIS includes contingency measures to be implemented in the even t that an exceedance of the 1978 lead NAAQS is measured at any TCEQ ambient air quality monitoring site in Collin County, or Exide reports an exceedance of 4.27 tpy in the annual emissions inventor y and that exceedance of 4.27 tpy was not the result of a p ermitted increase in lead emissions. If at any time during the second 10

- year maintenance period one of the above exceedances occurs, Exide will implement one of the following contingency measures within 180 days of notification by the executive director:

**•** automation of the scale and feed for the reverberatory furnace;

**•** installation of water misting dust suppression system beyond the system already required under permit 1147A; or

**•** an alternative measure proposed by Exide that results in emission reductions whi ch, at a minimum, must be equivalent to the emissions reductions achievable by the above contingency measures and approved by the executive director.

4.3 RACT AND RACM ANALYS IS

As published in the November 12, 2008, issue of the Federal Register (73 FR 67035), states containing areas designated as nonattainment are required to submit a SIP revision demonstrating that the associated enforceable control measures fulfill the RACT and RACM
requirements for sources of ambient lead concentrations.

In the September 1 7, 1979, issue of the Federal Register (44 FR 53762) RACT is defined as the lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and econo mic feasibility. Section 172(c)(1) of the Federal Clean Air Act (FCAA) requires states to provide for implementation of all RACM, including RACT, as expeditiously as practicable. In the General Preamble for implementation of the FCAA Amendments published i n the April 16, 1992, issue of

the Federal Register (57 FR 13498), the EPA explains that it interprets §172(c)(1) of the FCAA as a requirement that states incorporate into their SIP all RACM that would advance a region’s attainment date. However, regions a re obligated to adopt only those measures that are reasonably available for implementation considering local circumstances. I n the preamble for the lead NAAQS final rule ( 73 FR 67035 , November 12, 2008) the EPA provided guidelines to help states determine which measures should be considered reasonably available:

If it can be shown that measures , considered both individually as well as in a group,

are unreasonable because emissions from the affected sources are insignificant (i.e. de minimis), th an the measu res may be excluded from further consideratio n... the resulting control measures should then be evaluated for reasonableness, considering their technological feasibility and the cost of control in the area to which the SIP applies...In the case of public sect or sources and control measures, this evaluation should consider the impact of the reasonableness of the measures on the municipal

, or other

government al entity that must assume the responsibility for their implementation.4

- 4 The TCEQ used a two

- step process to develop the list of potential control strategies evaluated during the RACT and RACM analys e s. First, the TCEQ developed a draft list of potential control strategy concepts based on an evaluation of the existing point and fugitive sources of lead at Exide, the one contributing lead source in the Collin County lead nonattainment area. The draft list of potential control strategy concepts was presented to stakeholders for comment at a stakeholder meetings held in Frisco, Tex as, on January 19, 2011. The TCEQ requested comment on the potential control strategies and invited stakeholders to suggest any additional strategies that might help advance attainment of the Collin County nonattainment area. The final list of potential co ntrol strategy concepts for the RACT and RACM analyses includes the strategies presented to stakeholders, the strategies suggested by stakeholders during the informal stakeholder comment process, and control measures proposed or implemented at similar

seco ndary lead smelting facilities in other states.

Each potential control measure identified through this control strategy development process

was evaluated to determine if the measure would meet established criteria to be considered reasonably available. In addition to the criteria previously mentioned, the TCEQ also considered whether the potential control measure could be implemented prior to the November 1, 2012, date that Collin County must begin monitoring attainment in order to meet the December 31,

20 15, attainment date. As such, suggested control measures that could not be implemented by
November 1, 2012, were not considered RACM because the measures would not advance attainment. However, Collin County must make progress toward attainment of the 2008 lead NAAQS as expeditiously as practicable. Therefore, if a control measure can be implemented earlier than November 1, 2012, and will help the area make progress toward attainment of the 2008 lead NAAQS earlier than November 1, 2012, the measure should be implemented as early

as feasible.

The TCEQ also considered whether the control measure was similar or identical to control measures already in place at Exide. If the suggested control measure would not provide substantive and quantifiable benefit over th e existing control measure, then the suggested control measure was not considered RACM because comparable reasonable controls were already in place. The control measures determined to be RACT or RACM would be made enforceable through the adoption by the co mmission of Agreed Order 2011

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- MIS

.

4.3.1 Results of RACT and RACM Analysis

For RACM analysis, all potential applicable control measures for lead source types relevant to the Collin County lead nonattainment area were evaluated to determine if these control measures could be considered RACT and RACM and that the current proposed control measures outlined in this SIP revision fulfill the EPA RACT and RACM requirements (73 FR 67036).

In order to develop a comprehensive list of potential control strategies for t he RACT and RACM analysis, the commission solicited comment and input from stakeholders, including an informal comment and discussion at a stakeholder meeting held in Frisco, Texas

, on January 19, 2011. In addition, the commission evaluated existing and po tential measures at the Exide facility in Frisco and analyzed control measures proposed or implemented at similar secondary lead smelting facilities in other states. This analysis included the evaluation of existing and proposed

control measures at similar facilities such as the Exide Technologies facility in Vernon, California; the Quemetco, RSR facility in City of Industry, California; Gopher Resources in Eagan, Minnesota; Exide Technologies in Muncie, Indiana; and the Envirofocus facility in Tampa, Flori da. The TCEQ also commissioned a study of Air Control Technologies for Lead

Acid Battery Recycling by ERG and analyzed the control measures contained in the South Coast4

- 5 Air Quality management District Rule 1420.1, Emissions Standard for Lead from Large Lea d

Acid Battery Recycling Facilities.

Please see Appendix D: Reasonably Available Control Technology and Reasonably Available Control Measure Analysis

4.3.1.1 for a complete list of control measures and RACT and RACM

determinations.

The TCEQ has determined that f ull enclosures with negative ventilation sufficient to ensure that area fugitive emissions are routed to a high efficiency control device, in most cases a polytetrafluoroethylene (PTFE) membrane baghouse, is RACM and RACT for seco ndary lead smelting operations, including battery breaking operations, blast and reverberatory furnaces, refining and casting operations, slag treatment and fixation, and raw materials storage and handling areas. For some operations, high efficiency cartri dge filters are used instead of high efficiency PTFE membrane baghouses. Due to equivalent control efficiencies, cartridge filters used in place of PTFE membrane baghouses are considered RACM (including RACT). RACT and RACM Determination

The TCEQ has determined that operational work practices and housekeeping requirements that minimize fugitive lead

- d ust emissions to the ambient air, including traffic plans for materials loading and unloading, traffic plans that avoid areas with the potential to create fugitive lead

dust, inspection a nd immediate removal of leaking lead

- acid batteries upon delivery

, and the cleaning of equipment that is contaminated with lead inside of a permanent total enclosure prior to moving such equipment to a maintenance building is RACM and RACT for lead

- acid ba ttery recycling operations with secondary lead smelting and lead oxide operations.

The TCEQ has determined that wet scrubbers for battery breaker operations stacks and metallurgical scrubbers for furnace operations stacks with high efficiency PTFE membrane baghouses is RACM and RACT.

The TCEQ has determined that partial enclosure with negative pressure hooding and ducting to high efficiency PTFE membrane baghouses of lead oxide operations areas is RACM and RACT. The small amount of fugitive lead

- dust emissions associated with these operations justifies partial enclosures of lead oxide operational areas as a reasonable control measure.

The TCEQ has det ermined that w et electrostatic p rec ipitation (WESP) is not RACM or RACT for

lead

- acid battery recycling operations with secondary lead smelting and lead oxide operations.

WESP is not considered to be RACM or RACT due to its high cost and unproven performance with large particle sizes in the stack emissions of some secondary lead smelting operations. WESP has been installed at other facilities that include secondary lead smelting operations in

the United States to compl y with the AB258 8 Toxics Hot Spots program , a unique regulatory
requirement which specifi cally addresses cancer risk from a rsenic and other heavy metal

emissions

. In th at case, WESP may be a reasonable control technology and measure for facilities that operate electric ar c furnaces (EAF) as part of the secondary lead smelting process. E AFs operate at much higher temperatures (2500

- 3000 degrees Fahrenheit ) than the blast furnaces

used at Exide in Frisco. This higher heat volatilizes compounds such as arsenic and other heavy metals, while arsenic and other heavy metals (such as lead) are not volatilized in secondary lead smelting operations using blast and reverberatory furnaces. There is not sufficient information

to substantiate that WESP is reasonable for secondary lead sm elting facilities using blast and reverberatory furnaces at the additional cost of $17 to $25 million with the potential associated

lead reduction efficiencies estimated at 85 to 95 %

. In addition, the time required to design and install a WESP system would not allow for the associated lead emission reductions to be4

- 6 implemented before the date require for attainment of the NAAQS, disqualifying WESP as

RACT and RACM.

Agreed Order 2011

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- MIS, which is associated with this SIP revision, requires the

installa tion of high efficiency particulate air (HEPA) filters where technologically feasible as secondary control measures in addition to the primary control measure of high efficiency PTFE baghouses. The TCEQ has determined that the combination of HEPA filters as secondary control measures in addition to high efficiency PTFE membrane baghouses is not RACT or RACM. The level of estimated reductions and cost per ton of reductions of lead emissions associated with the addition of HEPA filters as a secondary control measure is not reasonable when compared to the reduction of lead emissions from the primary control of high efficiency PTFE baghouses used alone. This requirement is included in Agreed Order 2011

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- MIS as a voluntary control measures and is beyond RACT and RACM.

The TCEQ has determined that full e nclosure of lead oxide operations in conjunction with negative ventilation sufficient to ensure that area fugitives are routed to a high efficiency control

device is neither RACM nor RACT. The amount of fugiti ve lead

- dust emissions associated with lead oxide operations is insignificant and not sufficient to justify the determination of this

control measure as RACM or RACT.

The TCEQ has determined that partial enclosure of lead oxide operations areas in conjunct ion negative pressure hooding and ducting to high efficiency PTFE membrane baghouses is RACM and RACT. The small amount of fugitive lead

- dust emissions associated with these operations justifies partial enclosures of lead oxide operational areas as a reaso nable control measure.

The TCEQ has determined that the replacement of the hydraulic ram with a rotary screw feeder for the reverberatory furnace charging process is not RACM or RACT because it is not economically feasible given the minimal estimated emiss ions reductions. The level of reductions and cost per ton of reductions of fugitive lead

- dust emissions associated with this control measure is not reasonable for all secondary lead smelters. In addition, any emissions associated

with this source would be controlled through the furnace area enclosure. The measure was included in the Agreed Order as a voluntary control measure to advance and maintain attainment as expeditiously as practicable and is beyond RACT and RACM.

4.4 NEW CONTROL MEASURES

The new control measures needed for this proposed SIP revision to demonstrate attainment for the 2008 lead NAAQS in the Collin County nonattainment area would be made enforceable by Agreed Order 2011

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- MIS

.

Agreed Order 2011

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- MIS includes primary control measures a nd the associated implementation schedule as well as contingency measures to be triggered in the event of an exceedance “condition” (as defined in Agreed Order stipulation #10) of the 2008 lead NAAQS
after November 1, 2012.

Primary control measures for att ainment are included in the Agreed O rder under order stipulations 15 through 27

. Following is a list of primary control measures incorporated in the agreed order and their associated implementation dates.

**•** Relocate the slag treatment building to a location adjacent to the furnace and refining operations to reduce fugitive emissions. Replace the existing baghouse at the slag fixation operation stack (source 39) with a new baghouse fitted with PTFE membrane media and4

- 7 improved seating design or an equivalent or superior design if approved by the executive director, to be accomplished as expeditiously as practicable but no later than March 31, 2012. All baghouses must be maintained in good working order at all times.

**•** Fully enclose the battery breaker and covered raw materials storage area. This change will include the full enclosure of the battery breaker operations and contiguous covered raw materials storage area, the installation of negative pressure ventilation sufficient to ensure that the battery breaker and covered raw materials storage area fugitives are routed to the new baghouse, the installation of a new point source, and installation of a new baghouse with PTFE filter media and improved seating design bags, or an equivalent or superior design if approve d by the executive director. The enclosure performance shall be consistent with the requirements of 40 CFR §§63.544(b) and 63.547(e) as of March 7, 2011 . This measure is to be completed and operational as expeditiously as possible but no later than

March 3 1, 2012.

**•** Fully enclose and place under negative pressure ventilation the blast and reverberatory furnace area, including the refining/casting area (sources 10, 35, 36, and 37) as expeditiously as possible, but no later than November 1, 2012. This change will include the full enclosure of the blast and reverberatory furnace area, including the refining/casting area, the installation of negative pressure ventilation sufficient to ensure that blast and reverberatory furnace area fugitives, along with the re fining/casting area fugitives are routed to the new baghouse, the installation of a new point source, and installation of a new baghouse with PTFE filter media and improved seating design bags or an equivalent or superior design if approved by the TCEQ. Th e enclosure performance shall be consistent with the requirements of 40 CFR §§63.544(b) and 63.547(e) as of March 7, 2011.

**•** Complete the retrofitting of baghouses (sources 18, 21, 22, 23, 37, 38). Exide will replace all bags in the identified baghouses wit h PTFE membrane media and replace all of the baghouse tube sheets with improved seating design as expeditiously as possible, but no later than April 30, 2011, or an equivalent or superior design if approved by the executive director. All baghouses must be maintained in good working order at all times.

**•** Operate under a traffic plan for trucks unloading batteries at the facility and for traffic to,
from, and across the on

- site landfill. Exide will relocate the spent battery loading docks to

the north side of t he battery breaker operation and reconfigure the traffic route such that the spent battery delivery trucks enter and leave along the north route and never enter the center of the facility. Traffic excluded from this plan includes chemical delivery trucks, plant service vehicles, and other scrap delivery vehicles. This measure is to be completed and operational as expeditiously as possible, but not later than March 31, 2012.

**•** Replace the existing seals on the blast furnace “doghouse” emissions capture and ven tilation hooding system (source 10) as expeditiously as possible, but no later than April 30, 2011.

**•** Replace the reverberatory furnace (source 35) hydraulic ram feeder with a rotary screw as expeditiously as possible but no later than April 30, 2011.

**•** Insta ll a non

- fouling area misting system in the blast and reverberatory furnace area (sources 10 and 35) as expeditiously as possible, but no later than July 31, 2011. This misting system will stay in place until the furnace area enclosure is completed and the negative ventilation is operational.

**•** Fix and seal all holes and cracks greater than 15 square centimeters in surface area and at least 1.0 centimeter wide along the entire length of the opening in the existing secondary lead process and lead oxide operat ional area enclosures as expeditiously as possible but no later than March 31, 2012. Holes and cracks are defined as unintended openings in roofs and walls that occur due to corrosion or damage.

**•** Install secondary HEPA filtration at all of the baghouses tha t receive lead emissions (sources 11 through 18, 21 through 26, and 37 through 39) as expeditiously as possible, but no later than November 31, 2012. All filters shall be HEPA filters rated by the manufacturer to4

- 8 achieve a minimum of 99.97% capture efficie ncy for 0.3 micron particles and larger. For the full enclosures with negative ventilation, at least once each shift with each event not less than four hours apart, negative pressure monitoring must be conducted according to 40 CFR §§63.544(b) and 63.547(e ) as of March 7, 2011.

**•** Notification to the TCEQ’s Chief Engineer’s Office prior to submitting an application for a permit amendment that would allow Exide to increase site

- wide actual lead emissions above currently permitted levels in order to determine w hether an amendment to Agreed Order

2011

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- MIS or issuance of a new agreed order with corresponding SIP revisions are

needed.

**•** Continued maintenance of all air pollution abatement equipment to the level of good working order.

**•**

**•** Replace the existing roll

- up doors in the raw material storage building, as expeditiously as possible but no later than November 1, 2012. Upon receipt, any lead acid battery or palletized group of batteries that is cracked or leaking and is readily visible without removing shipping material, shall immediately be sent to the battery breaking area for processing or stored in a full enclosure kept under negative

pressure with emissions routed to a control device.

**•** Process or mobile equipment that is contaminated with lead shall be initial ly cleaned inside of a permanent total enclosure prior to being moved to the maintenance building. This measure shall be implemented by March 31, 2012.

Contingency m easures are included under Agreed Order 2011

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- MIS stipulations 10 (A) and 10(B). In th e event that on or after the three

- month period beginning November 1, 2012, an exceedance of the 2008 lead NAAQS is monitored at any TCEQ

- approved ambient monitor, Exide will be required to implement one or more of the following contingency measures as soo n as is expeditiously practicable.

**•** Full enclosure of the lead oxide operational area and installation of negative pressure ventilation and either a baghouse or cartridge filter (sources 11

- 17, 24

- 26, 46, 56

- 58). This

will include the full enclosure of th e lead oxide operational area, the installation of negative pressure ventilation sufficient to ensure that lead oxide operational area fugitives are routed to the new baghouse, the installation of a new point source, and installation of a new baghouse with PTFE filter media and improved seating design bags (see Attachment A), or equivalent or superior design if approved by the TCEQ. The enclosure performance shall be consistent with the requirements of 40 CFR §63.544(b) and 63.547(e) as of March 7, 2011.

**•** In stallation of vacuum hooding over lead oxide loading operations (currently Sources 27 and 28).

**•** Designate that wheeled and powered plant equipment such as forklifts used inside a fully

enclosed area will not be used outside of such an area.

4.5 MONITORING NETWORK

States are required by 40 CFR, Part 58, Subpart B, to submit an annual air monitoring network review (ANR) to the EPA by July 1 of each year. This network review is required to provide the framework for establishment and maintenance of an air quali ty surveillance system. The annual monitoring network review must be made available for public inspection and comment for at least 30 days prior to submission to the EPA. The review and any comments received during the

30

- day inspection period are then for warded to the EPA for final review and approval. The TCEQ posted the 2010 plan for public comment from June 1 through June 30, 2010. The TCEQ then submitted the plan to the EPA on July 1, 2010, for review and approval. The ANR document presented the curren t Texas network of ambient air quality monitors in Texas for4

- 9 which the TCEQ uploads data to the EPA’s Air Quality System (AQS), a nationa l database of air quality data.

4.5.1 Lead Monitoring Sites in Frisco

From 1981 until mid

- 1999, the TCEQ monitored lead level s at a residential location on Hickory Street in Collin County, Texas ( EPA AQS sit e identification code 480850001) , approximately

one

- half mile northeast of the Exide plant. Monitoring site 480850007, located at 6931 Ash Street, replaced the Hickory Street site in mid

- 1999 . Monitor 480850007 is a population

oriented site located in a neighborhood. Another site (480850009) was located on Exide property inside Exide’s security fence near the northern property line

, and a third site (480850003) was located on Exide property outside Exide’s security fence west of 5th Street. In July 2010, after meeting with the EPA to determine a location that EPA

- Region 6 found acceptable for the maximum

- concentration, source

- oriented monitor required by the rule establishing t he 2008 lead NAAQS, 480850009 was moved off Exide property and outside the company’s security fence so that it could be used to monitor ambient air. A s defined in Title 40 Code of Federal Regulations ( CFR ) Part 50.1, a mbient air means that portion of the a tmosphere, external to buildings, to which the general public has access . To meet EPA criteria for regu latory

ambient air monitor ing data , the following EPA criteria must be met :

**•** u se federal reference method (FRM), federal equivalent method (FEM), or approved regional methods (ARM) (40 CFR Part 58, Appendix C);

**•** m eet siting criteri a (40 CFR Part 58, Appendix E);

**•** m eet quality assurance (QA) requiremen ts (40 CFR Part 58, Appendix A); and

**•** meet data certification criteria (40 CFR Part 58, Subpart B).

Moni toring s ite 480850009 is currently located approximately 15 feet north of its previous

location on the exterior side of the Exide property fence line. In August 2010, site 480850003

moved to the east side of 5th Street in Frisco , and is now located on City of Frisco property

.

In addition to the monitors required by the EPA , the TCEQ installed a fourth lead monitor (480850029) located south of the Exide plant at the Frisco Police Station on Stonebrook Parkway. Site 480850029 commenced operations in January o f 2011.

Figure 4

- 1: Collin County Lead (Pb) Nonattainment Area shows ambient lead monitoring

location s in the Collin County lead nonattainment area, Frisco, Texas.4

- 10 Figure 4

- 1: Collin County Lead (Pb) Nonattainment Area4

- 11 4.6 CONTINGENCY PLAN

SIP revisions for nonattainment areas are required by §172(c)(9) of the FCAA to provide for specific measures to be implemented should a nonattainment area fail to meet reasonable further progress (RFP) requirements or maintain the 2008 lead NAAQS by the a ttainment date set by the EPA. The contingency plan must be enforceable and should identify measures to be adopted, a schedule and procedure for adoption and implementation, and a specific time constraint on action to be taken by the state. Additionally, t he plan should identify specific indicators or triggers that will be used to determine when the contingency measures are to be implemented. The intent of the indicators and triggers is to allow the state and Exide to take early action to remedy an actual o r potential violation of the 2008 lead NAAQS prior to the

attainment date.

The contingency measures are made enforceable in Agreed Order 2011

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- MIS.

4.6.1 Contingency Measures

4.6.1.1

**•** Full enclosure of the lead oxide operational are a and installation of negative pressure ventilation, new point source, and filtration media (either a baghouse or cartridge filter) (sources 11 through 17, 24 through 26, 46, and 56 through 58). The enclosure performance shall be consistent with the requir ements of 40 CFR §63.544(b) and 63.547(e) as of March 7,

2011. Contingency Measure Requirements

**•** Installation of vacuum hooding over lead oxide loading operations (currently sources 27 and 28).

**•** Designate that wheeled and powered plant equipment such as forklifts used inside a fully

enclose d area will not be used outside of such an area.

4.6.1.2

A contingency measure would be triggered upon failure to meet RFP requirements or failure to attain the 2008 lead NAAQS. Contingency Trigger Levels5

- 1 CHAPTER 5: R EASONABLE FURTHER PR OGRESS

5.1 GENERAL

Section 172(c)(2) the Federal Clean Air Act (FCAA) requires areas that have been designated nonattainment for criteria pollutants to include a demonstration of reasonable further progress (RFP) in attainment demonstration s. RFP is defined in FCAA §172(c)(2) as such annual incremental reductions in emissions of the relevant air pollution as are required by part D, or may reasonably be required by the United States Environmental Protection Agency for the purpose of ensuring attainment of the applicable National Ambient Air Quality Standard (NAAQS) by the applicable attainment date.

The 2011 Collin County Attainment Demonstration State Implementation Plan (SIP) Revision for the 2008 Lead National Ambient Air Quality Standard proposal would fulfill RFP for the Collin County lead nonattainment area through an ambitious compliance schedule which yields consistent and periodic significant emission reductions. This demonstration includes a detailed schedule for compliance of reason ably available control measures (RACM) including reasonably available control technologies (RACT) in the nonattainment area.

5.2 RFP DEMONSTRATION

As stated in the final lead rule (73 FR 67039), RFP is satisfied by the strict adherence to an ambitious complia nce schedule which is expected to periodically yield significant emission reductions. The control measures for attainment of the 2008 lead NAAQS included in proposed Agreed Order 2011

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- MIS (Appendix A) under stipulations 15 through 37, and listed under

4.4

, New Control Measures section of this proposed SIP revision have been modeled to achieve attainment of the 2008 lead NAAQS as described in Chapter 3: Air Dispersion Modeling

5.3 RACM AND RACT . The stipulations of Agreed Order 2011

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- MIS require these control measure s and resulting emissions reductions to be achieved as expeditiously as practicable, but no later than November

1, 2012.

The control measures for attainment of the 2008 lead NAAQS included in proposed Agreed

Order 2011

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- MIS under order s tipulations numbers 15 through 27, listed under Chapter 4

C ontrol S trategy and R equired E lements section 4.4

, New Control Measures , detailed under Chapter 4 C ontrol S trategy and R equired E lements section 4.3, RACT and RACM Analysis , and

included in Appendi x D : Reasonably Available Control Technology and Reasonably Available Control Measure Analysis of this proposed SIP revision are required to be implemented as soon as practicable but no later than November 1, 2012.

The Texas Commission on Environmental Qu ality (TCEQ ) has developed a detailed implementation schedule of the RACM (including RACT) control measures required in propos ed Agreed Order 2011

- 0521

- MIS. This schedule involves the expeditious implementation of all

control measures to assure attainment of the 2008 lead NAAQS by November 1, 2012. For the associated changes in ambient lead concentrations and percent contribution to ambient lead levels in the Collin County lead nonattainment area, please see Appendix E: RACM (including RACT) Control Measure Implementation Schedule for Reasonable Further Progress

.Appendi ces A vailable Upon Request

Holly Brightwell holly.brightwell@tceq.texas.gov

512.239.4905